Form 5500 must be filed for each benefit plan with more than 100 participants on the first day of the plan
year. It should be noted that the plan year and the policy year for benefits provided under insurance contracts are
not necessarily the same. Employers can use a “wrap” document to pull all employee benefits into a single plan
in order to reduce the number of Form 5500 filings required. The wrap document does not take the place of
other plan documents (such as the cafeteria plan document), it simply wraps all of the other documents
into one plan allowing all benefits to be reported within a single Form 5500 filing.

A Form 5500 filed for a wrap plan must include all benefits under the plan. Even those with less than 100
participants on the first day of the plan year are to be reported on Form 5500 since all benefits are
considered one plan.  The IRS penalty for late filing of Form 5500 is $25 per day, up to a maximum of $15,000.  The DOL penalty for late filing can run up to $1,100 per day with no maximum.  We partner with BASIC to offer this service, contact our office today for help!