2009 Form 5500 / Shc H & I Compliance Questions

[Jean]

Instructions for Line 4l: check 'yes' if any benefits due under the plan were not timely paid or not paid in full. Include in this amount the total of any outstanding amounts that were not paid when due in previous years that have continued to remain unpaid.

My list of contributions to report here include all nondiscretionary

Top heavy

QNEC

Money purchase from previous years (also reported on Sch R)

Safe Harbor required employer contributions

Employer match

Not salary deferrals because they are reported on 4a (failure to transmit participant contributions within the DOL timeframe)

Comments?

[Bird]

I don't have a copy of the form or instructions, but in your intro you refer to "benefits" due, but then list a bunch of contributions due.

[Jean]

Hmm...maybe I have been looking at this as contributions due when really they are looking for benefits/payments? Or am I just so confused because "provide any benefits when due" is not explained.

Line Item states:

4l. Has the plan failed to provide any benefit when due under the plan?

Instruction is check 'yes' if any benefits due under the plan were not timely paid or not paid in full. Include in this amount the total of any outstanding amounts that were not paid when due in previous years that have continued to remain unpaid.

[Bird]

I read it as "benefits due to a participant."