Affliiated Service Group question

[cpc0506]

We have a client who is a member of an Affliated Service Group. Law Firm X owns some of Title Company Y. We have determined that a ASG does exist. X and Y are both covered under Plan XY.

Now we have learned that Title Company Y is a control group with Real Estate Company Z. There does not exist a control group between Law Firm X and Real Estate Company Z (not enough common ownership). Company Z has a Plan Z that covers only Company Z employees. We are not the TPA for Plan Z.

What effect does the control group status between Y and Z have on the ASG between X and Y and the Plan XY?

[shERPA]

IMO X, Y and Z comprise a single employer for purposes of plan coverage, participation, non-disrimination, reporting, etc.

More info here:

http://benefitslink.com/m/qa.cgi?db=qa_who_is_employer&n=229