Is there any need for a qualified plan to have an EIN? The plan's trust may need an EIN to report distributions (if there's no corporate trustee), but the plan wouldn't seem to have any need for one. But a faint bell rings in my head -- have I heard not too long ago that the IRS wants us to get EINs for plans? Or is that just another sign of advancing age?

The entity sponsoring the retirement plan should have an identification number. It is also appropriate to have a separate tax identification number for the trust. Other that these two numbers, I am not aware of any other requirements.

If the plan administrator is something other than the sponsoring employer it needs an EIN as well.

Thanks for your help!