"wrap" plans and 5500 forms

Suppose an employer has been filing several 5500 forms - one for each plan - Dental, Disability, whatever. Has not been filing for certain plans due to less than 100 participants - say, Vision plan has only 40 participants.

Now they institute a "wrap" plan. Are they required to include the Vision participants, or can they still exclude them? Do they have the option to include or not include, and still file multiple 5500 forms, or must it be one form? I'd assume they want to file just one form, and must all sub-plans then be included?

This is a plan document thing and how its worded. Frankly, I would think you would want language including all programs automatically to avoid accidentally missing a filing when an excluded plan gets over 100. (A missed schedule A is an amended return. A missed filing is correspondence with the DoL and a penalty.)

Thanks. Haven't seen the wrap document, so I don't know what it says...

43 minutes ago, Alonzo Church said:

This is a plan document thing and how its worded. Frankly, I would think you would want language including all programs automatically to avoid accidentally missing a filing when an excluded plan gets over 100. (A missed schedule A is an amended return. A missed filing is correspondence with the DoL and a penalty.)

If you are doing a single filing because you have 1 plan with multiple benefits, that gets you to the missed schedule A. I can't imagine having a wrap plan document that still requires multiple 5500 filings.

One consideration for incorporating the Vision plan with less than 100 ee's into the wrap plan as a whole - by doing so, the Vision plan will not have an ERISA compliant SPD which it may not have otherwise.  The trade off of adding into the 5500 may be worth it.