Many of the 401(k) plans we service use contracts that have the account recordkeeping done by the "asset vendor". Examples would be the very popular "annuity contracts" made available for 401(k) plans by institutions including Guardian, ING, John Hancock, Hartford, Fidelity, Oppenheimer, Transamerica and T. Rowe Price (and others).

Under these contract you will find a fund selection naming funds of Neuberger & Berman, Fidelity, etc... You will also find proprietary funds that are offered by that institution. It has been my understanding that this type of arrangement does not result in self dealing, etc... and does not represent a transaction with a "party in interest".

Am I wrong? If so, why and how would this impact 5500 Reporting?

As always, thanks for your comments.

No takers on this one I guess. Well, I add this reply to keep it active for one more day. I know 4/15 is taking away my focus.