Reporting the Effective Date of the Plan

[Guest Beth1]

The 5500s that I'm currently working on are for the plan year 7/1/99 through 6/30/00. Our document does not allow for short plan years. If a new plan's effective date is prior to 7/1/99 and no contributions were made prior to then, would it be acceptable to state 7/1/99 as the effective date on the 5500 to avoid filing a form with zero assets?

This is the current policy and I don't feel comfortable changing the plan effective date on the 5500.

If there are no assets/receivables for the plan, must a form be filed?

Would it be acceptable to file a first return for the 6/30/00 plan year if the plan's effective date was 3/1/99?

[Guest Pam Gifford]

If the plan's effective date is 03/31/99 and the plan doesn't provide for short plan years, how do we get to a 06/30/00 plan year end? I feel like there is something left out.

[Guest Beth1]

All of our plans are on a plan year of 7/1 through 6/30. Currently, our document does not allow for any variation from this.

If an adoption agreement for a new plan states an effective date prior to 7/1/99, and if no assets have been contributed as of 6/30/00, our policy is to actually state the effective date as 7/1/99 on the 5500. This avoids us filing a form reporting zero assets for the period of 3/1/99 through 6/30/99.

We will then mark the 6/30/00 return as the first form filed for the plan (as well as marking the effective date as 7/1/99).

Is this acceptable?

[Guest Pam Gifford]

I can't say that I am an expert on that point. There are some who would say that you don't have a plan unless you fund it for the plan year. Why would someone write a plan for you with an effective date before the beginning of the plan year? If there is a good reason for doing that, there may be a reason for reporting the short plan year.