Schedule A required if all assets transferred mid-year?

[Cathy from Chicago]

The group annuity carrier (Company 1) sold all retirement assets on 6/30/01 to another carrier(Company 2); however, two schedule A's were produced, one by each insurance company. Even though no assets remain with Company 1, but commissions were paid, is a Schedule A required for this Company? Lastly, is a Schedule D also required for Company 1? Thanks in advance.

[JohnCheek]

Cathy, I think the correct way to file is: one Schedule A, because your company had one contract, even though it was transferred to a second company. The one Sched A would report all the data for the policy year that ended within the plan year, ie, combine the data from the two forms prepared by the two insurance companies.

However, if you chose to file two Schedule A's, that should not be a problem, either.

For Schedule D, I am assuming your money is in a pooled separate account... so the answer depends on whether Company 2 continued to administer Company 1's PSA, or whether Company 2 transfered those funds into it own PSA. (Since the only purpose of Schedule D seems to cross reference filing by plans with filings by DFE sponsors, the practical answer would be to do whatever the Sponsor did)

[Cathy from Chicago]

Thanks, John, for your post. I'll combine the two Schedule A's, I guess, and only put the NAIC code for Company 2 but include the commissions included from Company 1.