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Are 5500s required for terminated plans?


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Guest RogersSmith
Posted

My client has a DB plan that has been ignored for a number of years. His record keeping has been, to be kind, extremely limited. According to his records, his TPA (who ceased operations in 1993) prepared a PBGC form 500 in 1992 for plan termination. There are no records that the form 500 was actually filed with PBGC. The plan was fully funded at the time. My question is, if the plan was actually terminated, and the sponsor elected to continue the trust and distribute the benefits when due, is he required to continue filing 5500s? The last 5500 was filed in 1992.

Posted

Looks like the plan still exists. Yes, 5500s should have been filed. I wonder why the IRS has not sent a "where is your 5500" letter.

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

Guest RogersSmith
Posted

Yes, that was one of my questions. Maybe they were sent to the administrator's closed office; or maybe they fell into my client's black hole. Nevertheless, it looks like we have a long road ahead of us...eight years of 5500s with poor data, and a previous administrator that is providing no help. Thanks for your input.

Posted

someday we have to talk Dave Baker into adding a 'horror stories' board.

good luck!

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