Schedule I - Late Deferral Payments

[Guest revier]

I read an article in a recent issue of the ASPA Journal which encourage small plan filers, with late deferral contributions, to include an attachment detailing the late deposits and corrections.

Does anyone actually forward an attchement with the 5500? I thought you were not suppose to submit attachments.

A few years ago I used a 5500 program which allowed room for a one sentence comment at the bottom of schedule I. I used this one sentence comment section to disclose the plan had deposited the late deferrals with earnings.

Any comments would be appreciated.

[Bird]

My opinion is that it is a waste of time, at best. I think the argument for doing it is "it can't hurt." I'm not so sure.

The way I see it, they are not going to follow up on each and every return that indicated there were late deferrals. We've had more than just a couple and I only know of one that prompted a follow up, which was dealt with in about the time it would have taken to prepare the schedule. So I'd prefer to deal with the 1 out of 5 or whatever the ratio is, after the fact, than prepare each and every one. Also, I don't want to do anything that will gum up their delicate system. I have to think that a non-barcoded attachment is going to cause problems; maybe not directly related but I can just see another schedule getting messed up because of the monkey wrench.

And finally, my (limited) experience with the DOL is that they are, to be polite, not reasonable. I won't voluntarily give them anything, innocent as it may appear, that I don't have to.

Call me paranoid, but that's how I see it. I think the DOL guidance was strictly aimed at Schedule H filers and people are reading too much into it for I filings.

FWIW.

[Lori Friedman]

reviver,

The 2003 Form 5500 instructions state that delinquent payments, as reported on Line 4(a), are within the scope of the auditor's opinion and should be disclosed in the supplemental information to the financial statements.

Small plans, of course, are seldomly audited and don't attach their financial statements to Form 5500. I'm guessing that ASPA is recommending an alternative method for small plans, in the absence of an audit report, to provide the same sort of information about delinquent deposits.

If I'm right about this, I'd say that the ASPA suggestion is overkill and unnecessary. Large plans are subject to numerous reporting requirements that don't apply to small plans.