Schedule A Information for 5500-SF Filer

[5500sorBust]

If I am a 5500-SF filer, and my plan invests in the Pooled Separate Accounts of an insurance company, is the insurance company required to provide my TPA with Schedule A information?  I understand that I'm not filing a Schedule A as part of my 5500-SF, however, should the insurance company be providing full Schedule A information, or just information regarding commissions? 

[5500sorBust]

On 5/22/2020 at 1:10 PM, 5500sorBust said:

If I am a 5500-SF filer, and my plan invests in the Pooled Separate Accounts of an insurance company, is the insurance company required to provide my TPA with Schedule A information?  I understand that I'm not filing a Schedule A as part of my 5500-SF, however, should the insurance company be providing full Schedule A information, or just information regarding commissions? 

As a follow up...

I have reviewed CFR 2520.103–5,  however there is no indication if this applies only for large plan filers or 5500-SF filers as well.

[Bird]

It's hard to imagine them refusing.  We ask for, and get, Schedule A info all the time when all we really want is the commission info (for small plans).  It says "...as needed by the administrator to file the annual report..." so I suppose they could argue it isn't necessary.  But again, hard to imagine - is a company refusing?

[Mike Preston]

7 hours ago, Bird said:

It's hard to imagine them refusing.  We ask for, and get, Schedule A info all the time when all we really want is the commission info (for small plans).  It says "...as needed by the administrator to file the annual report..." so I suppose they could argue it isn't necessary.  But again, hard to imagine - is a company refusing?

Right, as usual.

[Lou S.]

They are required to provide it. Just because you are filing an SF, the insurance company really doesn't know if you have assets outside the contract that may make filling the SF impossible.

That said like Bird we get it, have never had any push back,  and simply report the commissions on the appropriate line on the SF.