Audit Requirements

[401king]

A plan previously hit the 120-participant threshold (years ago). As of 12/31/2012 the plan dropped below 100 participants so we are choosing to file as a small plan for 2013.

It is my understanding that once a plan has reached 120 participants they must file as a large plan until they drop below 100 participants. But, after dropping below 100 participants, is their threshold for a large plan filing going forward to be 100 participants, or 120 participants?

[GMK]

As I understand it, if you are at or below 120, you can file the way you filed the previous year ... which in your case, means your future threshold is again 120.

see page 7:

http://www.dol.gov/ebsa/pdf/2012-5500inst.pdf