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 DOL Issues Guidance on Schedule C Reporting for 2009 Form 5500 The U.S. Department of Labor’s Employee Benefits Security Administration (EBSA) released guidance to help plan administrators and service providers comply with the new requirements for reporting service provider fee and compensation information applicable to Form 5500 Annual Returns/Reports filed for plan years beginning on or after January 1, 2009.
EBSA released 40 frequently asked questions (FAQs) developed in response to questions from the employee benefit community on the new Schedule C requirements. The FAQs cover such issues as the alternative reporting option for eligible indirect compensation, electronic disclosure of fee information by service providers, fee reporting for brokerage window options in participant directed plans, and reporting on gifts, entertainment and other non-monetary compensation. The Department recognizes that it may be difficult for some service providers to make recordkeeping and information management system adjustments sufficiently in advance so that their systems will be fully operational when clients request data for their 2009 plan year Form 5500. Therefore, the department is not requiring plan administrators to report service providers on the Schedule C (for 2009) as failing to provide fee and compensation information under certain conditions. The service provider must furnish a statement that (i) the service provider made a good faith effort to make any necessary recordkeeping and information system changes in a timely fashion, and (ii) despite such efforts, the service provider was unable to complete the changes for the 2009 plan year. The FAQs on Schedule C reporting can be found at www.dol.gov/ebsa/faqs/faq_scheduleC.html. |
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| PO Box 5068 Troy, MI 48007-5068 Phone: 248.267.3700 Fax: 248.267.3737 E-mail: macpa@michcpa.org | |
