Schedule C Required???

[Cynchbeast]

We have a large plan for which we received TPA fees in excess of $5,000 in, but all money came from plan sponsor (corporate checking account), not the plan.

Does plan have to file a Schedule C for 2013 to report fees paid to us?

[Lou S.]

Schedule C is if for fees paid from the plan, not by the plan sponsor.

[Guest LauraVanSteeter]

For a large plan filer not including a Schedule C will generally result in a letter from the EBSA. In a brief conversation at a conference, they don't understand how a large plan could not have paid more than $5K in fees (direct and INDIRECT) over the year. The indirect fees are what is causing the confusion.

[Bill Presson]

We have a large plan for which we received TPA fees in excess of $5,000 in, but all money came from plan sponsor (corporate checking account), not the plan.

Does plan have to file a Schedule C for 2013 to report fees paid to us?

To Laura's point above, make sure you're including mutual fund operating expenses in the calculation. So your firm might not be included, but other entities might.

[My 2 cents]

For a large plan filer not including a Schedule C will generally result in a letter from the EBSA. In a brief conversation at a conference, they don't understand how a large plan could not have paid more than $5K in fees (direct and INDIRECT) over the year. The indirect fees are what is causing the confusion.

You might want to see how those holding/investing the assets are being compensated (and have no doubt, they are being compensated!). If they are being paid x% off the investment return or y% of the asset balance, not being shown as an explicit charge against the funds, they are obliged to have given the sponsor information documenting that.

Have you looked at the prior year's 5500 filing? Was there a Schedule C included? If not, it would seem that much less likely that not having one this year would raise flags, but sometimes they focus on things that had not been scrutinized before.

If there was no direct or indirect compensation to anyone from the plan, then you may be able to proceed without filing a C since you know there is nothing to report.