Schedule C

[DPL]

Has anyone received a notice on a DC plan for failure to file a Schedule C? No change in acct or actuary. No indirect comp paid to any vendor. Total direct comp $3000. EBSA is sending a notice asking why the Schedule C was not filed.

[Guest banjo picker]

Has anyone received a notice on a DC plan for failure to file a Schedule C? No change in acct or actuary. No indirect comp paid to any vendor. Total direct comp $3000. EBSA is sending a notice asking why the Schedule C was not filed.

Yes, one of our clients received such a letter. Datair currently has a thread going on this topic.

Apparently more than 500 such emails were sent. I find it interesting that the initial contact was by email since we have been conditioned to believe that the government (or at least the IRS) does not originate emails such as this.

As best we can tell, if Schedule H reported certain assets, such as mutual funds, DOL assumes that the plan MUST have paid direct or indirect comp and should have filed a Schedule C. I'm not sure how the plan can prove to DOL that no one received more than $5,000. Will they just take our word for it or is there some other means of proving Schedule C was not required?

[Bill Presson]

We had a client get a notice as well. We're just going to file an amended return instead of argue about it.

[Guest LauraVanSteeter]

Reasoning may be that it would be hard for a large plan to not have 'eligible indirect compensation' of under $5,000.