Gilmore Posted May 21, 2019 Share Posted May 21, 2019 A small, calendar year cash balance plan purchases life insurance in November 2018. The insurance company says a Schedule A will not be completed until November 2019. Assuming the 2018 commissions will be listed on the Nov 2019 Schedule A, is it acceptable to wait until the 2019 5500 to enter 2018 commission amounts on Line 10e Part V of the SF? Or do we press the insurance company to provide the commission amount paid in 2018? Thanks very much. Link to comment Share on other sites More sharing options...
Bri Posted May 21, 2019 Share Posted May 21, 2019 Clearly not if that means waiting past the end of the filing deadline. And if it's a 12-31 contract year, doesn't the insurer have only 120 days to provide it? And were the commissions actually paid in 2018 rather than actually IN 2019? Luke Bailey 1 Link to comment Share on other sites More sharing options...
Pam Shoup Posted May 21, 2019 Share Posted May 21, 2019 Have you tried asking the insurance agent? Pamela L. (Bobersky) Shoup CEBS, RPA, QKA AMI Benefit Plan Administrators, Inc. 100 Terra Bella Drive Youngstown, Ohio 44505 800-451-2865 www.amibenefit.com Link to comment Share on other sites More sharing options...
C. B. Zeller Posted May 21, 2019 Share Posted May 21, 2019 How about answering 10e "no" (or yes/0) and then amending the filing if/when the carrier provides the updated info? WDIK 1 Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance. Corey B. Zeller, MSEA, CPC, QPA, QKA Preferred Pension Planning Corp.corey@pppc.co Link to comment Share on other sites More sharing options...
Peter Gulia Posted May 21, 2019 Share Posted May 21, 2019 Here’s a quotation from the statute: If some or all of the information necessary to enable the administrator to comply with the requirements of this title [I of ERISA] is maintained by an insurance carrier or other organization which provides some or all of the benefits under the plan, or holds assets of the plan in a separate account, . . . such carrier [or] organization . . . shall transmit and certify the accuracy of such information to the administrator within 120 days after the end of the plan year[.] ERISA § 103(a)(2)(A), 29 U.S.C. § 1023(a)(2)(A). https://www.govinfo.gov/content/pkg/USCODE-2017-title29/html/USCODE-2017-title29-chap18-subchapI-subtitleB-part1-sec1023.htm Luke Bailey 1 Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com Link to comment Share on other sites More sharing options...
Gilmore Posted May 22, 2019 Author Share Posted May 22, 2019 Thank you for the replies. My only contact is the advisor who sold the policy, who is trying to be helpful. I do not know if the commissions were paid in 2018 or 2019, that's what I've been trying to find out, and so far just received the reply that the Sch A would not be prepared until this year. I'm assuming that since the insurance was purchased in November 2018, the contract year ends November 2019. I will keep pushing for clarification on when commissions were paid. Thank you. Link to comment Share on other sites More sharing options...
unfunded Posted May 22, 2019 Share Posted May 22, 2019 I believe the Schedule A information to be reported is for the contract year ending in the plan year. If the contract year ends in November, then the first Schedule A required will be for the 2019 5500. Link to comment Share on other sites More sharing options...
chc93 Posted May 22, 2019 Share Posted May 22, 2019 We've had insurance policy Schedule A's that reported commissions/fees in one year, and none in the a following year. We've answered the 5500 question appropriately with "yes" or "no" based on what the Schedule A reported. Now, if this is the first year and a Schedule A was not provided, I would probably answer "no". Link to comment Share on other sites More sharing options...
Gilmore Posted May 26, 2019 Author Share Posted May 26, 2019 Thanks again for the information. Unfunded, thank you for that clarification. Link to comment Share on other sites More sharing options...
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