Schedule of Reportable Transactions necessary?

[Guest dmcmanus]

I have a plan which is merging it's assets into another existing plan. The investments are non-participant directed, therefore under normal circumstances a Reportable Transactions schedule would be required. However, I'm wondering since the investments are not being "sold", they are merely being transferred to another plan under the same TPA, same custodian, etc, would the schedule be required?

Does anyone have any knowledge/past experience with something like this?

Thanks in advance!

[WDIK]

This is only my opinion, but I do not think that a reportable transaction occurs if the assets are merged into another plan and no sale or purchase has ocurred.