Plan merger reporting - GRRR!

This may be more of an annoyance than a real problem. Let's say a plan merges (into a PEP) on October 2, 2024. But the assets aren't liquidated until October 12, and not actually "transferred" until 3 days later - October 15..

Now, my understanding has always been that the technical "last day" of the plan year is the effective date of the merger agreement. That is (arguably, depending upon who you are dealing with) the day that the assets "belong" to the new plan, even though the technical transfer doesn't take place until somewhat later. But the auditor wants to see the date of the "final" as being the date of the physical transfer of the fund, therefore showing a balance of zero as of (in this example) October 15th.

Is there really any problem with just showing the final date of the form as October 15th? Seems like it'll keep everyone happy and have no real effect on anything?  

I assume this has to do with how the Form 5500 is completed.  It is an annoyance.  If should be using full accrual accounting which would get the plan to zero no matter which date is used for the plan year.

Technically, the plan year ended on the merger date but the trust continued.  If the trust also was considered merged on the merger date, then the assets belonged to the new plan.  If not, then the trust persisted after the merger date.

What really matters is that if the Form 5500 has the Final Return box checked, then the ending balance on the Schedule H must be zero.  The transfer of assets also is disclosed on Schedule H. 

Whether the plan year is entered as 10/2 or 10/15 is not a big deal, nor is the cost of professional time that the client could get charged for "discussing" the issue.

And, by the way, the client can decide since they are signing the form under penalty of perjury (and it is okay if the audit report differs from the form as long as the difference is explainable).

I would put the date of the transfer as final day. I mean often times we terminate a plan as of X date but the last distribution day is X + Y and we we report the date of the last distribution that closed the trust as the last day for 5500. I see this as an analogous situation.

Thanks to you both!