Schedule SSA for year of merger: past participants reported again?

[John A]

Am I correct that, when Plan A is merged into Plan B, all participants that had been reported on past Schedule SSAs for Plan A (and have not yet been paid or forfeited) should be reported on the Schedule SSA for Plan A in the year of merger as Code C?

[Kristina]

According to the instructions for the SSA, you should report any of the previously reported deferred vested terminees on the Sch SSA as filed for the recipient plan. (Page 52 of the 5500 instructions) This updates the SSA records to direct those requesting Social Security benefits to the recipient plan instead of the old merged plan which will no longer exist.

If a plan is terminated and all funds are distributed to participants and terminees, you should also file a corrective SSA using Code D. (See instructions for Sch H and Sch I Items 4k and 4j respectively.)