FAQ 180: 5500 -- Plan number 001 or 002?

Problem: If the client had a qualified plan which was terminated a few years ago and then started a new qualified plan in 2017, should the new plan number be 002?

Solution: Yes, under the conditions you present, the next plan number would be 002. "The three-digit plan number (PN), in conjunction with the EIN, is used as a unique 12-digit number to identify the plan or DFE. Although EINs are obtained from the IRS, the plan sponsor/ employer or plan administrator assigns the PN. Also, once a three-digit plan number and your EIN is used for one plan or DFE it cannot be used for any other of your plans or DFEs, even after the plan or DFE terminates." Page 16 of Troubleshooter's Guide to Filing the ERISA Annual Report (Form 5500 and Form 5500-SF) https://www.dol.gov/sites/dolgov/files/ebsa/about-ebsa/our-activities/resource-center/publications/troubleshooters-guide-to-filing-the-erisa-annual-report.pdf