A “funded” welfare benefit plan (a plan funded through a trust, such as a VEBA) is always required to file Form 5500, regardless of the number of employee participants. An “unfunded” welfare plan (a plan with no assets, which pays benefits from the general assets of the plan sponsor, or a fully-insured plan or a combination of both) must also file Form 5500 unless it qualifies for an exemption. There is an exemption for unfunded plans, fully-insured plans or combination unfunded/fully-insured plans with fewer than 100 employee participants on the FIRST DAY of the plan year. If a plan qualifies for this exemption, then no Form 5500 is required for that plan year.