4T - Multiple Employer Code

[5500Nerd]

Hello, We have a group that is a MEWA and has 15 employer contribute. They are not under a trust. Is 4T to be used under 8b? It has over 10 employers but when I read up on its definition: 10 or more employer plan under Code section 419A(f)(6) and then read on 419, 419A and 419A(f)(6), it talks about a funded plan. However when I called the Efast Customer Service and the Office of Chief Accountant they did not know. They referred me to the Office of Regulations and Interpretations. This office does not call back consistently. Does anyone have any insight to help? 

 

Many thanks