Form 5500 DFE

[DTH]

I have a few questions on Form 5500 filing requirements for Master Trusts.

1.) If I have a plan sponsor that has more than one plan and the assets of all the plans are all in a directed trust at a bank,that trust is considered a master trust. Yes/No

2.) Master trusts are now required to file Form 5500. The master trust will file as a DFE. Yes/No

3.) If a bank holds, as a directed master trust, assets for many plan sponsors with multiple plans (e.g., the bank holds assets for plan sponsor A (that has 3 plans), plan sponsor B (that has 6 plans), plan sponsor C (has 2 plans), does the DFE file one form 5500 for all the plans (i.e., Schedule D will show a total of 11 plans) or three separate Schedule Ds.

4.) Do the instructions require that the master trust files all ten plans of the three plan sponsors on one Form 5500 Schedule D, where the master trust will only need one nine-digit EIN and one three-digit plan number. [Example - Bank EIN 12-3456789, Plan Number 001) Yes/No

5.) Do the instructions require that the master trust must file three separate Form 5500 Schedule Ds for the three plan sponsors, where the master trust will need one nine-digit EIN and three three-digit plan numbers for each plan sponsor. [Example - Bank EIN 12-3456789 (for Plan Sponsor A - Plan Number 004), (for Plan Sponsor B - Plan Number 007), (for Plan Sponsor C - Plan Number 003)] Yes/No

6.) Do the instructions require that the master trust must file three separate Form 5500 Schedule Ds for the three plan sponsors, where the master trust will need three separate nine-digit EINs and separate one three-digit plan number for each of the three EINs. [Example - (For plan sponsor A - Bank EIN 12-3456789, Plan Number 001), (Plan Sponsor B - Bank EIN 12-3456790, Plan Number 001), (Plan Sponsor C - Bank EIN 12-3456791 Plan Number 001)] Yes/No

7.) It appears that the plan sponsor can elect the three-digit plan number? Yes/No

7.) It appears from the DFE Filing Requirements on page 10 for the 2001 Form 5500 instructions, that the plan administrator is responsible to ensure Form 5500 is filed for the MTIA.

"Master Trust Investment Account (MTIA)

The administrator filing a Form 5500 for an employee benefit plan is required to file or have a designee file a Form 5500 for each MTIA in which the plan participated at any time during the plan year."

Who can the designee be?

8.) According to the instructions on Page 6 for Form 5500 a representative can sign on behalf of the DFE.

"A representative authorized to sign on behalf of the DFE must sign the Form 5500 submitted for the DFE."

What type of authorization is acceptable (e.g., is verbal authorization acceptable?) If the DFE does not authorize anyone to sign, what should the plan administrator do since it is the plan administrators ultimate responsibility to ensure the Form 5500 is files for the DFE????

Thanks

[JanetM]

DTH - I think I can answer some of your questions by explaining something. I will use some examples -

Our Company sponsors 6 DC plans - 4 are in MT at bank. I file 5500 for each plan and one 5500 for master trust (a DFE).

The 5500 for the MT lists the asset details. For example - we have 4 common collective (cc) funds (who file as DFE themselves) and we have 2 investment managers who do not file as DFE. On the Schedule H - I can list the cc funds on the line for investments in common collective. The actively managed accounts must be detailed by asset class.

The bank (the directed trustee of the MT) does manage one cc fund - a money market fund. They file a 5500 for the cc - listing all the plans or master trusts in the fund. The bank do no file a separate 5500 for each master trust that invests in the cc fund.

Does that help?