"Not all welfare plans are required to annually report on Form 5500 or Schedule C. A plan that covers less than 100 participants at the beginning of the plan year -- and which is unfunded, fully insured, or a combination of both -- is exempt from the annual reporting requirement. See [DOL] Regulation section 2520.104-20 and 2009 Instructions to Form 5500, page 4. Where such a welfare plan has 100 or more participants at the beginning of the plan year, it is subject to the annual reporting requirement but is not required to file Schedule C."