Top Hat Plan Registration Statements - Plan Spinoff

[M_2015]

Is a new registration statement required where a portion of a top hat plan is spun-off in connection with the spin-off of a subsidiary whose employees participate in its parent's top hat plan?  

[CuseFan]

Spun off as in a new employer with a new EIN and now that new company is responsible for those NQ benefits? I would say yes as it is a new plan established by a new employer.