SOP 94-4-1 & Form 5500

[Guest LauraVanSteeter]

Plan is invested in a CCT that is subject to the new 94-4-1 requirements. CCT files as DFE.

What amount is reported on the Schedule H & D, FMV or Contract value??

[JanetM]

From the AICPA audit guide.

ARA_Appendix_D_re_FSP___SOP_94_4_1.pdf

[Guest ak]

My understanding is that based on past DOL guidance and current Form 5500 instructions, for Form 5500 reporting purposes, reporting for investments held through a CCT, etc. has not changed to date. Thus, reporting on Sch. H, etc. relating to the CCT is at fair value. Form 5500 reporting does include a contract value exception for fully benefit responsive investment contracts, but from what I can see, that only applies currently to fully benefit responsive contracts issued to the plan by an insurer, see Sch. A and Sch. H instructions.

[sbutler]

From the AICPA audit guide.

I have a 401(k) invested in the Wells Fargo Stable Value Fund S. I know the financial statement valuation is contract value. What value should Sch H, line 1©9 be at? Per 5500 instructions it is current value, but Wells is reporting it at contract value.