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Posted

Assuming the top-hat exemption was filed with DOL when the plan was established, is there a requirement to notify them of a termination?

Any sites on this would be tremendously appreciated...

Austin Powers, CPA, QPA, ERPA

Posted

Not a cite affirmatively saying "no filing is required" but 29 CFR 2520.104-23 says a top-hat plan "shall be deemed to satisfy the reporting and disclosure provisions of part 1 of title I [of ERISA]" if the plan sponsor files the required top-hat letter with DOL and provides plan documents to DOL upon request. 

Posted

no requirements I am aware of---remember that DOL's online registration filing only began a couple of years ago--I had several of the first 20 filings with them. Before that, my sources told me they were housed in a warehouse someplace and not really reviewed.

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