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Form 5500, Schedule C


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Posted

My understanding has always been that the only expenses paid by the plan (as opposed to the employer) be reported on the Schedule C. The thinking being that the C allows the DOL to monitor the fiduciaries of the plan. Therefore, in filing a 5500 for a self-insured medical plan whose funding vehicle is through general assest, no Schedule C is required to report third party administrator fees. Is this correct or do these TPA fees need to be reported on the Schedule C?

Posted

I agree that Schedule C is not required for the fact pattern that you describe. If it was included with the 5500, it would create a problem because the DOL would try to match the fees described in Schedule C to the fees listed on Schedule H. However, Schedule H would not be required for the type of arrangement you describe, thus probably resulting in the DOL sending a notice to the filer in order to resolve the matter.

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