Schedule A - fail to provide any information checkbox

[TPApril]

Just looking for thoughts, opinions? New clients' prior 5500s seemed to use Schedule A Part IV item 11 liberally and check off Yes with ease when that was not the case. Think it should be amended and if so all the way back to 2009? To what extent is the IRS following up on this question? if they do, to what extent do they identify to insurance companies those plan sponsors who checked off Yes?

[Andy the Actuary]

Perhaps this is style? When I suspect issue with prior filings, depending upon the seriousness of the issue, I indicate to client that they should bring opinion to attention of prior service provider and make it incumbent upon prior service provider to correct filing, if applicable. The client should not have to pay me to make correction. This issue may have a different response if a defined benefit rather than a defined contribution plan.

In your situation, what did the Schedule A report in item 12, which is required to be completed if item 11 is checked "yes?"

[TPApril]

This is a welfare plan (wish there was a 5500 forum dedicated to welfare plan issues). in one case they actually reported a non-ERISA covered benefit which i think should be removed in an amended filing. in another case in 2009 that commissions were not reported, though they had everything else.

[Bill Presson]

What is the real risk if the IRS or DOL question it? I'm not in favor of filing incorrect 5500s, but it it's not material, I would likely look at letting it lie.

[TPApril]

That's what I'm trying to assess - it is so easy (and affordable) to amend a 5500, if there is some kind of exposure here. Plan sponsor in question wants to make sure they did not create risk to insurance co.