"Preparing to start a DFVCP filing for the plan years 2019 through 2023. The plan was terminated during 2019. There were twelve participants (all with balances) at the start of the 2019 Plan Year. At the end of 2019, there were two participants remaining and one of the two had an ending account balance of only $0.75. We plan to amend the 2018 Form 5500-SF for a couple of reasons. In the process, can we 'not count' the participant with the $0.75 balance in the participant counts at the end of the 2011 Plan Year? Would it make any difference? Let's say we do count the participant with the $0.75 balance at the beginning of 2019, and the account custodian took the $0.75 as a fee in Jan-2020. Then there was only one participant with a balance, and that participant still has a balance today (May-2025). Can we file a Form 5500-EZ for 2019 if our inactive participant count is two on Jan-01 but only one on Dec-31? Keep in mind that we are filing under DFVCP beginning with the 2019 return. If we must file a Form 5500-SF for 2019, can we then file Form 5500-EZ for the remaining years through the plan's final return?"

"There's a question on the 5500-SF: Has the plan failed to provide any benefit when due under the plan? If a plan did not process the mandatory cashout, do we answer yes? The 5500-SF instructions only reference RMDs. But does it include other distributions? Like the cashouts? Or when someone requests a distribution but it languishes for some reason."