Existing plan joins a MEP.

[Belgarath]

We have not encountered this - first time for everything! I am, however, unsure of the exact process. So, our client joins a MEP with someone else effective (X) date - let's just say November 10. Assets will be liquidated from current investment provider, and transferred into the MEP - exactly how, not sure we care. My question is re the 5500 SF. Is the 5500 SF filed as a "final" showing the transfer on Lines 13(b) and (c)? Or would it be a full year 5500 SF since the plan isn't being "terminated." And would it be filed as a short plan year as of the date of transfer of the assets? It appears that no 5310-A would be required.

Just not sure of the process. Would it just be the new MEP that would file a 5500 for 2024, and we wouldn't file a 5500 at all? It'll be driven by the new TPA anyway, but I'd like to get a better handle on how this typically is/should be handled.

Thanks!

[Peter Gulia]

Without answering your reporting questions:

Don’t assume the multiple-employer plan’s administrator would accept responsibility for anything beyond the MEP’s Form 5500 report.

Consider carefully what services (if any) your service agreement or engagement letter provides about reporting on the single-employer plan’s accounting period of January 1, 2024 to November dd, 2024.

Other BenefitsLink neighbors might tell you what customs of the trade have developed.
 

[RatherBeGolfing]

1 hour ago, Belgarath said:

So, our client joins a MEP with someone else effective (X) date - let's just say November 10. Assets will be liquidated from current investment provider, and transferred into the MEP - exactly how, not sure we care.

Sounds like a plan merger to me. (Im assuming they are not leaving a MEP or PEP with you which would add some complexity)

1 hour ago, Belgarath said:

Is the 5500 SF filed as a "final" showing the transfer on Lines 13(b) and (c)?

Yes, because you have to let the IRS/DOL know to not expect another 5500-SF for this EIN+PN.  

1 hour ago, Belgarath said:

And would it be filed as a short plan year as of the date of transfer of the assets?

Yes.

1 hour ago, Belgarath said:

Would it just be the new MEP that would file a 5500 for 2024, and we wouldn't file a 5500 at all? It'll be driven by the new TPA anyway, but I'd like to get a better handle on how this typically is/should be handled.

Depends on service agreement with the client.  Our default is that prior provider will file the final 5500 since they have the data, but we will do it for them if the client/provider relationship has soured to the point where the prior provider says "not my problem" or if the client asks us to do it.  

[Belgarath]

Thanks. Very helpful.

[FishOn]

 This may be a silly question, but we have a similar situation except that the plan is moving to a PEP.  @RatherBeGolfing do you think the answers you provided be the same?

[RatherBeGolfing]

1 hour ago, FishOn said:

 This may be a silly question, but we have a similar situation except that the plan is moving to a PEP.  @RatherBeGolfing do you think the answers you provided be the same?

Yes.