Schedule D

[Christopher Wilson]

Hello everyone - is anyone aware of having to no longer complete Schedule D for a large plan with assets invested in a Transamerica group annuity? According to Transamerica, no Schedule D is required because Transamerica is not a Direct Filing Enitity (DFE) and, therefore, the plan's assets should be reported as being held by a registered investment company (Schedule H, Line 1c(13)) rather than being invested in pooled separate accounts. Thank you for your assistance.

[chc93]

For 2018 calendar years, Transamerica still provided their Schedule D download file... so we are filing Schedule D's... I guess we'll continue until Transamerica stops providing the download file... or tells us to stop.  We haven't heard anything from them yet.