My firm has called the Comptroller's office multiple times and spoken to different agents and each has said if the combined group is under the 2.47M limit then each affiliate now has to file it's own public information report since there is no combined report to file.  That should mean we delete all the affiliates from the combining entity's affiliate screen and file the PIR for each entity on its own.  If the combined group had 4 affiliates, we are now filing 5 separate PIR's instead of one return with 5 PIR's attached.  Seems like a lot more work for us but that's what the state is telling us.