5500 Schedule D

[PhilB]

I recently received a DOL notice requesting that my company file a Schedule D for the 2000 plan year as the preparer last year specified on Schedule H that our plan(s) contain DFE assets. I have the collective trust information. My question: Do we need to list all funds that held assets last year or only those that held assets as of December 31, 2000? Also, I have heard that investments in mutual funds do not have to be listed - true? Both of these pieces of information came from the Trust Company who files Part 2 of Schedule D.

[Guest Robin Vatalaro]

It is also my understanding that mutual funds do not have to be reported.

Joe Canary (one of the 5500 drafters at the PWBA) has stated at conferences that you must report all funds (PSA's, CCT's, etc) that had $ during the year even if zero balance at year end.

[PhilB]

One other question: Line e (Dollar Value of interest) would seem to be the same number as line 1c(11) in Schedule H - But can you use the aggregate dollar interest at year end or do you have to use the interest specific to the investment for each collective trust?

[Guest mcapcpa]

I agree with Robin. The Form 5500 Schedule D requires to list all DFE's on even if the balance is zero at the end of the year.

Another red flag that alarms the DOL that you would need to file a Schedule D would seem to be if you reported any income or loss in items 2b (6) thru 9 on Part II of schedule H. On these lines you will trigger to the DOL that you held a DFE during the year. even if you reported zeroes in Part I line 1c (9) through (12).

[PhilB]

I called the DOL in DC - They require employers to list EVERY investment for the pension/401k plan(s) throughout the plan year (INCLUDING mutual funds), even if there are zero dollars in the investment as of December 31, as well as the dollar value of interest applicable to each investment as of December 31. I was also able to clarify a misunderstanding on my part: that the term "interest" - which I took to mean the return on investment - is actually the total financial stake in a particular investment. In other words, the total dollar value of the fund (principle plus any investment earnings) at year end.

[PhilB]

Talk to DOL and you find out more than you want to know. DOL has told me that not only do we have to file a 5500 as an employer plan, but also as a Master Trust entity, also with a Schedule D. And depending on the nature of the funds within the Master Trust, we could end up filing separate 5500s for all of the investment funds. All in addition to our plan filing - all in the name of administrative simplification. Yikes!