Schedule D, and line 1(c) on the Schedule H.

[Belgarath]

This Schedule D stuff makes me cross-eyed.

Probable takeover case where a Schedule H is required, and one question led to another, ad infinitum - you know the routine.

Plan investments are all through the "John Doe" Trust company, which allows participants to direct their accounts by purchasing only mutual funds. They are limited to (x) funds - I believe around 50 of them.

I find the form 5500 instrructions and DOL regs referenced to be somewhat less than a model of clarity on Schedule D and DFE issues. The Trust company does NOT file a 5500 as a DFE, and they say that a Schedule D is not required as this is not a PSA, or a CCT, etc.

This is the conclusion I also rather belatedly arrived at, although I originally expected the opposite. But since this is the first time I've wrestled with this particular question, I'd appreciate any comments from others who may have gone through this same exercise. Do you agree or disagree that a Schedule D is not required? And assuming not, then the value of the funds should be listed on 1©(13) on the Schedule H?

Thanks in advance!

[Harwood]

"Schedule D must be attached to a Form 5500 filed for an employee benefit plan that participated or invested in one or more common/collective trusts (CCTs), pooled separate accounts (PSAs), master trust investment accounts (MTIAs), or 103-12 Investment Entities (103-12 IEs) at anytime during the plan year."

I see nothing about mutual funds or registered investment companies. I don't think Schedule D needs to be filed in your case. [Neither the Trust Company or the Mutual Fund companies would be DFEs.]