New HRA - no participants in 2017 - 5500 required?

[t.haley]

Client instituted retiree HRA effective 1-1-17.  The plan has no participants and no contributions/assets in the plan.  Is a Form 5500 required?  Do I simply file a Form 5500-SF with zeros for participants, assets, liabilities, etc.?

[Flyboyjohn]

Hopefully your client didn't set up a trust so there will never be "plan assets" and it will be an unfunded  welfare benefit plan paid from employer general assets and exempt from filing until the participant count goes over 100.

So no 2017 5500 and depending on size of participant population maybe no 5500 ever.

 

 

 

[t.haley]

There is a trust in place to fund the retiree HRA when it gets participants, but no contributions have been made - so we don't qualify for the exemption for a unfunded welfare plan.  My inclination is the file the 5500-SF showing no assets, no contributions, no participants.  I completed a 5500-SF on EFAST and the system "validated" it.  Any harm in filing the 5500-SF this way?

[Flyboyjohn]

Why in the world did they set up a trust? Have they filed for tax exemption for the trust? Unless they're a huge company with huge dollars involved a trust sounds like a mistake.