2023 Start up plan 5500 audit requirements

[MicheleH]

I've not had much luck finding an answer to this, hoping the contributors here can help me - with the change in methodology of participant count for the 2023 Form 5500, now looking at participants with a balance as of the beginning of the year, how will this impact new plans that have 0 participants with a balance as of the beginning of the year but over 100 at the end? I found one line from Ascensus that stated a first year filing would look to participants with a balance on the last day (which makes sense to me, otherwise all new plans would be small filers). However, I can't find that stated on any governmental site. Has anyone looked into this or have a link to postings from the IRS/DOL? 

Thank you!

[C. B. Zeller]

See the rule published at 88 FR 12048 (page 65 of the pdf here: https://www.govinfo.gov/content/pkg/FR-2023-02-24/pdf/2023-02653.pdf)

DC plans use the number of participants with a balance as of the first day of the year to determine if they are a small plan or a large plan, unless they check the box for first return/report, in which case they use the number of participants with a balance as of the last day of the year.

[MicheleH]

Thank you so much, this is exactly what I could NOT find!