New Plan Audit Requirement for Large Plan status

[Pammie57]

is there any relief for a plan that started late in 2014 and didn't realize they would be required to get an audit due to large plan status until after year end? they do have over 120 eligible participants and have not engaged an auditor as of today for their 2014 pye.

Plan started in September with calendar year end.

[My 2 cents]

Would they qualify under 29 CFR 2520.104-50 to wait until next year to attach? There would still be some requirements to satisfy, but it sure sounds like a 2-consecutive plan year period with one of the two plan years being less than 7 months long. The 2015 5500 filling would have to include an accountant's report covering both the short 2014 plan year and the full-length 2015 plan year. Would that help?

[Lou S.]

If 2014 was a short plan year, yes you can do what My 2 cents suggests.

If the plan was adopted in September retroactive to January 1st (to get full year limits for 415 & 401(a(17)) pretty sure you are going to need an audit for 2014.

[Pammie57]

Per plan document - first year was a SPY - Sept 1 through Dec 31, 2014. Not retroactive to 1/1.

Thanks for your replies.