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MTIA / Master Trust Investment Account Setup


5500sorBust

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Is anyone familiar with guidance regarding the setup of a Master Trust Investment Account (MTIA)? 

One of my main questions is - should the plan sponsor's EIN be used on the DFE 5500 filing for the MTIA?  And then, say the sponsor only has plans 001 & 002 (that will be investing in the MTIA), would the MTIA then assume plan number 003?  It would appear so, according to the Form 5500 instructions, which seem to be the only source of instruction.  If anyone is aware of specific MTIA guidance outside of the Form 5500 instructions in general, it would be much appreciated.  Thanks!    

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We had client with multiple DBPs (3) that used a master trust and the MTIA 5500 was filed under the sponsor's EIN and plan number 005 (DBPs were #1-3 and there was a DCP for #4). This goes back 10 years as they had terminated the plans but I don't think those rules have changed.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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I always understood that a trust should have its own EIN, for purposes of any tax filings required for the trust. This article has some thoughts on the matter. https://www.policygenius.com/trusts/ein-for-a-trust/

Also the DOL specifies the "EIN of the Trust" in this language. They also refer to how you can use the next Plan Number in the series.

https://www.dol.gov/agencies/ebsa/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/forms/efast2-form-5500-filing-tips#:~:text=In the case of a Form 5500 filed,Investment Entity (IE) or Group Insurance Annuity (GIA).

 

The above is my opinion only, not anyone else's.

I'm not a lawyer nor do I play one on TV.

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