Schedule C- Relationhip To Employer

[austin3515]

So the recordkeepers always enter "Recordkeeper" on their Schedule C reports under the field for their own relationship to the Employer. I believe the DOL has said publicly that that's not what they mean - they mean something beyond their relationship as a service provider (which relationship is already obvious).

Can anyone point to something? I already checked the 2 FAQs and found nothing...

[Peter Gulia]

For Schedule C's line 2 element ©, the text on the Schedule and the instruction [page 27] refer to a relationship to the plan's sponsor, an employer, an employee organization, or another party-in-interest.

The instruction gives four examples of relationships: (i) employee of employer, (ii) vice-president of employer, (iii) union officer, and (iv) affiliate of plan recordkeeper.

Each of those examples refers to a relationship that exists separately from the fact of providing a service to or regarding the employee-benefit plan.

I recently reviewed a Schedule C in which this element's reporting on the custodian, investment manager, accountant, lawyer, and recordkeeper all were "none".

[austin3515]

I recently reviewed a Schedule C in which this element's reporting on the custodian, investment manager, accountant, lawyer, and recordkeeper all were "none".

That is what we do too, but because so many providers will indicate "Recordkeeper" I was hoping the DOL clarified in a more "obvious" manner. Almost all of them indicate their service provider role as the relationship.

[Peter Gulia]

If you presentation remarks on ambiguities, here's another:

Schedule I part II line 4g asks "Did the plan hold any assets whose current value was neither readily determinable on an established market nor set by an independent third party appraiser?" If the answer is Yes (and none of the exceptions applies), the instructions say: "Enter in the amount column the fair market value of the assets referred to on line 4g[.]"

Is the amount to be reported the sum of the end-of-year values? Or is it the highest values during the year?

If it's end-of-year and the plan disposed of all of the 4g assets before the year's close, does one report the amount as $0.00?

[chc93]

I recently reviewed a Schedule C in which this element's reporting on the custodian, investment manager, accountant, lawyer, and recordkeeper all were "none".

That is what we do too, but because so many providers will indicate "Recordkeeper" I was hoping the DOL clarified in a more "obvious" manner. Almost all of them indicate their service provider role as the relationship.

We have always entered "None" in this element ©. We never had a service provider that had such relationships as noted in the instructions. Also, element (b) provides codes for the services rendered.