Wrap plan document - variable start dates

[TPApril]

Plan sponsor is setting up a wrap plan document eff 1/1, but some of the benefits are not expected to exceed 100 covered ee's until the following year. Rather than report on the 5500 for all benefits, they'd like to design the wrap plan to include 3 given benefits the first year and additional benefits the next year. Is there reason why not?

[dashab]

A wrap plan bundles all benefits into one. If any one benefit provided under the plan exceeds 100 lives, all benefits will need to be reported for the year on the Form 5500.