Schedule B filing

[Gary]

Regarding 1 participant plans that file form 5500ez.

Say the plan has less than 250k a 5500ez is not required.

My understanding is that it is not required to provide the client with a Schedule B.

I have some clients that do not want the Sch B since they do not want to pay for it.

We charge $300 for the B. Valuation charged separately.

Any comments on how others handle this type of situation?

Thanks

[JAY21]

You have revised your valuation rates and they are now $X (old val rate plus $300).

[carrots]

Regarding 1 participant plans that file form 5500ez.

Say the plan has less than 250k a 5500ez is not required.

My understanding is that it is not required to provide the client with a Schedule B.

I have some clients that do not want the Sch B since they do not want to pay for it.

We charge $300 for the B. Valuation charged separately.

Any comments on how others handle this type of situation?

Thanks

The instructions on page 4 of the 2008 Form 5500-EZ, Schedules, says that the Schedule SB must be provided to the person responsible for filing the Form 5500-EZ.

[Gary]

Our firm charges a fixed amount for the valuation.

And an additional fixed amount for the 5500ez.

So if the 5500ez is not filed we then prepare the B only and charge $300.

However, some clients do not want Sch B since they do not want to pay for it.

I'l rephrase my questions.

Is it required to supply the client with a Sch B? Again no 5500ez reequired since under 250k and client does not want 5500ez either.

Would other practioners provide the B to client saying that it a necessary deliverable or handle it some other way?

Thanks

[rcline46]

No reputable enrolled actuary would do ANY db plan without doing the Schedule B. You need the B to prepare next year's B. Eventually the assets will exceed $250,000, the EZ will have to be filed, and the prior year's B (SB) will be needed.

[Effen]

I agree with rcline. In my opinion the Schedule B IS the valuation. It is clearly required that you prepare the Schedule B, even if it is not filed. It is also clear that the filer must retain the completed Schedule B so I think you need to send it to them. If they choose not to accept it, that isn't your problem, but I think you are obligated to provide it.

I think charging for the Schedule B seperately implies it is a la carte. Kind of like ordering a meal and then having them charge you extra if you want to actually eat it. It just seems a little misleading.

From the EZ instructions:

Note. Effective beginning with calendar plan year 2005, filers of Form 5500-EZ are no longer required to file any schedules or attachments (including the Schedule B (Form 5500)) with the Form 5500-EZ. Filers, however, must collect and retain completed and signed Schedule B, if applicable. This change does not eliminate the requirement to both perform an annual valuation and maintain the funding standard account for all plans subject to the minimum funding requirements of section 412.

From the Sch. B instructions (2007):

Note. The Schedule B does not have to be filed with Form 5500-EZ (in accordance with the instructions for Form 5500-EZ under the "What To File" section); however, the funding standard account for the plan must continue to be maintained, even if the Schedule B is not filed.

[Gary]

I agree with the above.

I have a client that does not want to be provided the Schedule B because he does not want to pay the fee.

Thanks.

[Gary]

The client asked via email "who requires the Schedule B to be delivered and maintained"?

As far as I know the IRS does as per their instructions for Form 5500EZ. Not sure of any specific regulation requiring the delivery of the Schedule B.

Anyone know of any?

This inquiry pertains to the 2007 plan year.

Page 4 of the 2007 5500EZ instructions states in the section labeled "Schedules", "The completed Schedule B is subject to the record retention provisions of these instructions. See the instructions for Schedule B (Form 5500)."

Does anyone know precisely where the record retention provisions are found?

Thanks.