Schedule C -- An intriguing matter

[Lori Friedman]

Do you report aggregate groups of employees, rather than individual employees by name, on Schedule C?

One of my clients has a legal opinion recommending this approach. The opinion is based on information provided by two DOL employees who spoke at a pension/benefits conference. Both of the DOL employees said that Schedule C's purpose is to report significant payments to service providers, not to list such very personal information on a publicly-disclosed document. Conference attendees were instructed to take employees with reportable compensation, lump them together in broad categories such as "administrative" or "executive", and report the aggregate amounts on Schedule C.

The Schedule C instructions certainly don't suggest this approach. In fact, the instructions say to use the employer's EIN (rather than individual social security numbers) when reporting employee compensation; this instruction suggests that each employee gets reported separately. And, since when is DOL so concerned about confidentiality? Form LM-2, another publicly-disclosed DOL form, reports some very explicity information about employee compensation.

On the other hand, the IRS prepares the Schedule C instructions, and the DOL could have a very different postion.

Has anyone else encountered this issue?

[JanetM]

Few years back I worked on a number of VEBAs. In reporting employees on schedule C I used EIN and not employees SSN. We never lumped the employees together.

Have seen how Multiemployer plans do the same and use the EIN, but then I have seen them use SSN too.

INHO as long as instruction say to list them, I would.

This is interesting topic, waiting to see if anyone else was given that advice too.

[Ron Snyder]

Thank you for raising an important issue that has bothered me for many years. Not that we have any expectation of privacy, but it seems offensive to show enough information on a public form to facilitate identity theft.

[Guest anagpal]

As per 2004 instructions for 5500, SSN number are not allowed to be used on any of the schedules except Sch SSA (for reporting separated participants). Because of the privacy concerns, the inclusion of SSN on Sch C or any of its attachments may result in the rejection of the filling.