Schedule of Reportable Transactions

[Guest SPOT]

Am I supposed to include interest bearing cash as a reportable transaction (>5% of plan assets)?

[Guest Emiliano]

The mere existence of interest bearing cash does not constitute a transaction.

[BeckyMiller]

Do you mean does a shift of funds from interest bearing cash to another investment choice have to be included on the more than 5% transactions?

One of those questions that has been unanswered since the Form 5500 series first developed. A member of the DOL's chief accountant's office once told me that anything that is listed as an investment on Schedule H is considered in the reportable transaction disclosure. This is line 1© of schedule H and it includes interest bearing cash.

If you look at the intent of the schedule, however, I think you get a good sense of the answer. The schedule is looking for major shifts in investments, churning, etc. As such, depositing funds into interest bearing cash that are then withdrawn and invested in a long-term vehicle shouldn't require 2 disclosures - the liquidation of the interest bearing cash and the purchase of the other investment. On the other hand, if your interest bearing cash is actually a money market fund and it is a long-term investment vehicle in today's chaotic market, maybe it should be.

Sorry - non-response, response.

[Guest SPOT]

Thanks Becky.

This is a case where there were numerous purchases and sells of a money market fund that the trustee reported on it's "reportable transaction" report. I have never included interest bearing cash with my reportable transactions before, but the plan auditor questioned why they weren't included.