H&W plan's Form 5500 filing requirement when number of employees drops below 100

[R. Butler]

Health & welfare plan has always had to file a 5500 because they were over 100 participants.  At the beginning of 2016 they dropped down to 85 participants.  Generally they would not have to file a 5500, but does the fact that they had filed in prior years necessitate that they continue to file?

Thank you for any guidance. 

[Flyboyjohn]

Ideally prior year 5500 would have contained code 4R ("we ain't filing next year) but if it didn't you need to choose between filing current year with code 4R (my recommendation) or wait and see if you get a "where's your 5500" letter and then explain the situation.

If it turns out you'll be back over 100 next year I'd just file for current year to keep the EFAST computers happy.