What happens to 5500's filed separately for participating employers in

[MR]

Now that 5500 season is in full swing, here's a question about a multiple employer plan filing for 1999. The IRS instructions clearly state on page 10, under Box A(3) that "Participating Employers do not file individually for these plans." You are required to file a separate Schedule T for each participating employer according to the instructions. My question is, what happens to all of the participating employers that filed separate 5500's for 1998? Will the IRS or DOL come looking for a 5500 for a plan of a participating employer in a multiple employer plan that no longer needs to file under the new rules?

[Disco Stu]

In past years, I believe that the proper way to file for a multiple employer plan was that one Form 5500 was filed for the plan as a whole. The plan number was to be 333. Then a separate Form 5500 C/R was attached for each participating employer.

It seems to me, they have the information from the previous years' forms to know what to expect this year. I can only assume that since the IRS/DOL designed this process, they will know how to administer it. If not, that's their problem.