Schedule C Requirement

[Vlad401k]

Must all mutual funds held in a large plan during the year be reported on Schedule C with their tax ID? How does the $5,000 requirement come into play? For instance, let's say the participants within a plan hold 30 different mutual funds throughout the year. The TPA received, let's say $100,000 in management fees for the entire year. Should all of the 30 mutual funds be listed on Schedule C?

[Vlad401k]

Any thoughts?

[Peter Gulia]

The usual way an SEC-registered investment fund or its service provider might be mentioned in a Schedule C is not necessarily as a service provider to the plan but rather as a "person [that] provided you [the plan's administrator] disclosures on eligible indirect compensation".

That there are 30 funds does not necessarily mean that there are 30 persons that furnished disclosures.

For example, if six of the 30 funds have Strategic Advisers or Fidelity Management & Research as a fund's manager, all of those funds might have Fidelity Distributors Corporation as the funds' underwriter, and FDC might be the person that furnished EIC disclosures.

The instructions state: "[P]rovide as many entries in line 1b as necessary to identify the person or persons who provided you [the plan's administrator] with the necessary disclosures regarding the eligible indirect compensation."