Help - Schedule D / Schedule A Confusion

[Guest lawdawg]

We received Schedule D reporting stating that we have a PSA that must be reported. We also received a Schedule A from the same insurer listing unallocated insurance contracts of the same dollar amount as was listed for the PSA. How do we complete the Schedule H when it comes to reporting unallocated insurance contracts and PSAs. Obviously, if I put the amounts in for both the PSA and the unallocated insurance contract in the Schedule H I'm out of balance with the plan finanicals by the same amount. Did I get bad info from our insurer or am i just confused? We determined that our 5500 preparer had no clue because they backed into a number to get the Schedule H to balance with the financials. Now we are trying to clean up this mess. Any help would be greatly appreciated.

[WDIK]

The Schedule A instructions for lines 6a through 6f indicate that you should "not include portions of these contracts maintained in separate accounts" for those purposes. Although a similar statement is not found in the Schedule H instructions, such an approach would seem logical.

It is possibile is that your situation could have something to do with the following caution and note from the Schedule H instructions for line 1c(10).

CAUTION! The plan’s or DFE’s interest in CCTs and PSAs for which a DFE Form 5500 has not been filed may not be included on lines 1c(9) or 1c(10). The plan’s or DFE’s interest in the underlying assets of such CCTs and PSAs must be allocated and reported in the appropriate categories on a line-by-line basis on Part I of the Schedule H.

Note. For reporting purposes, a separate account that is not considered to be holding plan assets pursuant to 29 CFR 2510.3-101(h)(1)(iii) does not constitute a pooled separate account.

Another option (although most likely fruitless based on personal experience) is to try and get a clarification from the insurance company that issued the information.