Separating a Multiple-Employer Plan...With a Twist

[Gadgetfreak]

Company A sponsors the Company A 401k Plan. Through common ownership (but not enough for a controlled group) Company B adopts the Plan and it is now a Multiple Employer Plan. There is an unsigned joinder agreement we inherited from a prior provider.

Company A want to move to a PEO. They want to leave the Plan in place for Company B to take over as the Sponsor. So a new Sponsor Name, EIN and Plan Name must be done via amendment. If I really wanted to be clean, I could create a whole new set of plan documents. Company B doesn’t want to terminate the plan (and create a distributable event) as they want all assets to remain in the plan.

They want this change effective 4/1/14.

What amendments did you think should be done to facilitate this change? What changes should be done on the 2014 5500? If I do new documents, what nuances can you think of? Any other advice? Thanks.