5500 - Schedule C reporting

[Alex Daisy]

I am a TPA and having a hard time getting the requested Schedule C Fee Disclosure information from various Investment Managers / Custodians.

Are they legally required to provide this information and what legislation / documentation can I site that will show they that they are legally required to disclose the fees?

Any help is grealty appreciated.

[Andy the Actuary]

Only suggestion is since we are gnats, direct the correspondence to your client and indicate that the investment managers have not provided it. It is the client who will be signing the 5500 and not you. It is best if you can identify the penalties (I suspect that an incomplete 5500 is synonymous with a 5500 not filed?) that the IRS/DOL could assess by law.

Then, after you do all this, you still won't get the information but you'll know you operated in a responsible manner.

[Bird]

Part II can be used to provide information on service providers who failed or refused to provide Sch C data. Before it came to that, I think I would send a letter formally requesting the info with a remark that if it is not provided, it will be so reported. Also note that FAQ 40 allows the service provider to just say they can't provide the data due to their inability to adapt their systems in time.

Yes, the client needs to be part of these conversations.