Master Trust Investment Accounts

[Guest Mark DeBoer]

We have historically filed separate Form 5500s for separate investment options (funds) that are used in our various defined benefit and defined contribution plans. However, in preparing this year's 5500, I noticed that some of the funds contain a unitized investment in a portfolio that is shared between multiple funds and I am concerned that this may be treated appropriately.

My question is a follows:

Is it appropriate to prepare separate 5500s only at the unitized fund level or alternatively at the unitized investment manager level?

Attached is an excerpt from page 11 of the 2008 Form 5500 instructions. I have read this several times, but the treatment seems unclear.

The assets of a master trust are considered for reporting purposes to be held in one or more ‘‘investment accounts.’’ A ‘‘master trust investment account’’ may consist of a pool of assets or a single asset. Each pool of assets held in a master

trust must be treated as a separate MTIA if each plan that has an interest in the pool has the same fractional interest in each asset in the pool as its fractional interest in the pool, and if each such plan may not dispose of its interest in any asset in the pool without disposing of its interest in the pool. A master trust may also contain assets that are not held in such a pool. Each such asset must be treated as a separate MTIA.

Any help or clarification related to this issue will be greatly appreciated.