H&W 5500's - wrapping multiple 5500's into one & plan years

[TPApril]

Plan Sponsor currently files all H&W benefits in separate 5500's.

Plan Sponsor is going to adopt a wrap plan document effective 1/1 of current plan year.

Prior plan year 5500 has not been filed.

I'm getting dizzy thinking about this - how to include Schedule A's and incorporate counts to make the change.

I'm thinking:

• Prior Year - because wrap plan not yet effective, file as normal, with counts reflected at eoy
• Current Year - all individual plans will file as Final and show both beginning and end of year counts of 0 and no Sched A's. New Plan will have an opening participant count and all Sched A's in the new plan

[Bug on my window]

When is the wrap effective? Is the wrap going to be a continuation of one of the existing plans?

If it's 12/31/prior-year, and the new plan is effective 1/1/current-year, then you will have final 5500 filings needed for all plans that are not continuing. The Prior Year 5500 will need to show zero headcounts at year end (as all final filings do) and have the final filing box checked.

If the wrap will be effective 1/1/current year, instead of 12/31, then I believe you are setting yourself up for a one-day 5500 filing.

Note that the Schedules A follow the same rules as always. They should be included for the plan year that ends within the contract year. 

Other folks smarter than I may have other opinions. Take this for what it's worth, free advice.

[TPApril]

Wrap will be adopted this year and effective 1/1 of current year. It is too late to make it effective 12/31 of prior year.

Planning to make the wrap plan a brand new plan, rather than continuation of prior one.