Master Trust Final 5500 Filing

[jenny.paulson]

I have a client who previously had a Mater Trust account prior to moving to our company. When they moved to our company in 2014, the master trust was dissolved and just the individual plans remain. A final 5500 filing was submitted for the master trust; however, it was well past the due date. The individual plan 5500 filings were submitted on time. I understand that there is not a DFVCP process for master trusts; however, does anyone know if there will be IRS penalties for late filing? DOL suggested we write a letter to attach to the 5500 filing requesting the fees to be waived. Where can I find such a sample letter? Thanks!

[jpod]

Isn't the master trust filing voluntary, in which case how could there be a penalty? I think the risk stemming from the master trust not filing timely is that the underlying plans' 5500s could be deemed deficient (assuming they took advantage of the rules relieving them of the obligation to report information on the master trust's holdings and p&l).

[jenny.paulson]

Thank you jpod for responding. According to what I can find, 5500 filings are required for MTIA (which this one is) and is not required for CCTs, PSAs and GIAs. I would think the risk would still be associated with the underlying plans (filed timely); so, I am still on the hunt for more information on the delayed filing process for MTIAs.