Seeking advice on "wrap plan" drafting

[Guest myarbrough]

I need some guidance on a "wrap plan". I have never drafted one but have been given the SPDs for 3 welfare plans and have been asked to wrap the plans so that only 1 5500 needs to be filed. At this point my understanding is that I need only create a document which contains the ERISA reqd language and references the SPDs for each plan in the appendix. Any help or material on this matter would be appreciated.

[KIP KRAUS]

Just my thoughts, without looking up anything, but if all three plans currently have separate three digit plan numbers I would thank you would have to cancel two of them and then combine the three under one plan number in order not to have to file each plan separately.

Once this is done, I agree that each SPD could be separately listed in an appendex to a wrap document, but in my opinion if you maintain three separate plans, even if described in a wrap document, you would still have to file separate 5500s for each plan. That is the way we have ours set up.

[Kirk Maldonado]

I wrote an article on wrap plans many years ago. The citation is Why An Insured Health Plan Requires a Wrap-Around Document, 3 Journal of Compensation and Benefits, 147 (1987).