Plan 002 with an Earlier Effective Date than Plan 001

[KJJ-TPA]

We have a situation where a client has a new safe harbor match plan "001" with a 1/1/22 effective date with a bundled provider. They will be moving from the original service provider to our firm and. in order to meet their objectives, we will be setting up a profit sharing only plan (cross tested/new comp) and then merging the plans effective 1/1/23. They would like to setup the new profit sharing plan, with a retroactive effective date of 1/1/21. I'm wondering if anyone sees any issues with the new plan, eff. 1/1/21, being plan 002 even though it has an earlier effective date than plan 001? We'll be skipping the 2021 5500 filing for this plan and the first 5500 filing will be for the second plan year (2022).

[Lou S.]

Other than it being a quirk of how the plans were adopted, I don't see a problem if that's what you are asking.

[CuseFan]

Although most people's usual convention, there is no requirement to order plan numbers sequentially according to their effective date or the date actually adopted.

[KJJ-TPA]

Thank you both!