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I'm preparing a Form 5500 for a plan that uses the Nationwide Trust Innovator Fund, a platform within which an employee may pick among mutual funds. Interests in the Innovator Fund are unitized. So, the plan owns units of the Innovator Fund.

Nationwide insists that the Innovator Fund is not as a pooled separate account (PSA) or collective/common trust (CCT).

Is the interest properly reported as interests issued by a company registered under the Investment Company Act of 1940 (e.g., a mutual fund)? That is, is the Nationwide Trust Innovator Fund a mutual fund of mutual funds and reported as a mutual fund itself?

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