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Hello, When a single employer plan merges into a MEP, the single employer plan files a final 5500. If the employer later decides to spin off from the MEP into a newly established single employer plan, can that employer use the original Plan Number (001) and effective date of the original single employer plan (prior to the merger)? I have a single employer Plan (effective 01/01/2017 / Plan 001) that merged into a MEP in 2021. A final 5500 was filed for the single employer Plan for a short plan year in 2021. The employer has decided to spin off from the MEP into a newly established single employer plan in 2023. Can the single employer Plan use the original effective date of 01/01/2017, and IRS Plan Number 001, or should the effective date be the date the assets spun off from the MEP with a Plan Number of 002? Thank you!

My understanding of the rules are that they clearly state: What date to use to pro-rate That the Simple catch-up is included in the pro rata calculation. And that's it. the 401(k) catch up is apparently missing (as in not mentioned), and that there's no clear instruction or guidance on whether or not you need a short plan year, that compensation must be prorated and that the 415 limit must be prorated. Is that correct? Thanks