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Bobclp
What are the requirements for "top-hat" welfare plans? Could be more or less than 100 participants. Initial filing? Annual Reports?
jpod
If you're using the term "top hat" to mean a welfare plan that satisfies the exemption from the reporting and disclosure rules set forth in the DOL's regulations, there is nothing to file, regardless of the number of participants.
Bobclp
Yes, it would satisfy DOL's regulations. So am I correct that there is not even an initial notice to DOL to notify that there is a plan, like there would be with a top-hat pension plan?
jpod
You are correct.
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