Schedule C Required???

[Andy the Actuary]

I will be submitting a 5500 without a Schedule C because there is no information to report. Will EFAST2 reject the filing?

[Lou S.]

If no schedule C because nothing to report, why not submit a Sch C with only plan identification and info blank?

If no schedule C because info was not provided, that's a different story.

[BG5150]

Just don't check off Sched C as an attachment in question 10 on the 5500. Wouldn't the algorithm feed off of that?

[Andy the Actuary]

Appreciate the thoughts but it looks like no one else has dealt with this issue?

[12AX7]

If there is nothing to report, then BG has provided you the answer . You don't always need a Schedule C with a 5500. Let's us know if we're missing something in your question.

[Andy the Actuary]

Sorry to be so dense. I find nothing in the instructions to 5500 to suggest you don't have to include a Schedule C. It seems obvious since you wouldn't include Schedule A if no insurance or Schedule SB after the plan termination year. I was simply concerned that EFAST2 might reject a filing without a Schedule C. I guess I can try filing without a Schedule C and see what happens though this would mean checking back on EFAST2 at a later date to ensure all is copacetic.

[12AX7]

Andy, I have filed a number of 5500 forms with and without Schedule C. Are you using Relius or other software that does edit checks? If you indicate that there is no Schedule C attacment, it will pass the edit check. Yes, you can also check the status of the filing after it has been completed, but the vendor software is very reliable.

[Andy the Actuary]

Thank you. That is helpful. I use "Ifile" under Relius.

[Kevin C]

http://www.relius.net/News/TechnicalUpdates.aspx?ID=907

The article probably doesn't match your situation, but it does indicate there are situtations where the Schedule C is not required.

[sam2012]

I would be very careful about filing a 5500 (long form) without a schedule C. You can do that way but when you really look at a plan, chances are that there was indirect fees received by someone. In fact a the DOL last year sent out a number of inquiries to filers who had not attached a schedule C. We file a schedule C with every plan. I can only think of a few sceanrios where you woul dnot file a Schedule C (e.g. a new plan just starting up, a very small number of active participants).