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Ok, not the rules but here is my take on the 5500. Do whatever you want it is immaterial to spend this much time thinking about it. What I would do is not include it in the ending assets as it was paid and move on. But if the CPA doing the audit (assuming it is even an audited plan) said put it in the ending assets I would give them what they want without any additional thought. Too small of an amount to care about. I have never seen an IRS or DOL audit of a 5500 that has ever looked at the assets of a plan hard enough to get into this issue.

Nope. They provide you with the means to maintain your own document. There is a big difference. They do not make sure the document is properly filled out, or that you make timely amendments, or that you keep all necessary documents in a safe place, etc. That is all on you. Trust me, the people who frequent these boards have taken many Vanguard and Fidelity plans through correction programs for this very reason.