Schedule D - when to file?

[Guest ForteT]

I have read the instructions for the new Schedule D quite a number of times and I am still not understanding in exactly what instances this schedule is necessary.

IS this something that needs filed with most of the forms?

For example, I have a few plans with invesments in Manulife. Manulife sends out a one page instruction sheet for completing the schedule D. I understand that they are an insurance company and the funds are in pooled separate accounts.

What about mutual funds such as those held by Fidelity, American Funds, Schwab, etc?

Are these pooled separate accounts or common collective trusts? The assets of many plans are held under one umbrella so to speak.

I would be so grateful if someone could clarify this confusion for me. If you could give examples of master trusts, common collective trusts, etc. that would be great.

[Guest Emiliano]

1) Master Trust: a master trusts only holds the assets of two or more plans of the SAME employer (or of related employers).

2) Common Collective Trusts and Pooled Separate Accounts: Federal Register Vol. 65, No. 76 dated Wednesday, April 19, 2000, amended the DOL regulations. Section 2520.103-5 was amended to require all CCTs and PSAs to notify its participating plans whether it intends to file Form 5500 and to furnish the plan administrator with the information needed by the plan to satisfy its filing requirements. Thus, if your plan invests in a CCT, then the CCT is required to provide the information you need (i.e. whether it intends to file, EIN, etc...). Unfortunately, there is no provision in the regulations to enforce this requirement.

3) 103-12 Investment Entities: this can get complicated. From your seat, you probably don't have enough information to determine whether the funds you invest in are 103-12 IEs. The only way is to inquire directly from the entities themselves. For example: 25% of the value of its equity interests have to be held by benefit plan investors. You can't know whether the other investors in a mutual fund are benefit plans or indian chiefs.

4) Schedule D: your plan must file Schedule D if it invests in a master trust, CCT, PSA or 103-12 IE. If it doesn't invest in any of these, then it doesn't have to file Schedule D.

The DOL is sometimes helpful. Call them at (202) 219-8770.

[Guest Sonia Kapoor]

The instructions say that Schedule D is required for all DFE's....I am new to this field and haven't yet been able to figure out what exactly constitutes a DFE...If a DFE decides to file Form 5500 for a plan do the other individual sponsor also need to file a separate filing for the same plan?

[Guest Emiliano]

Sonia, I suggest you read the instructions to the 1999 Form 5500 especially pages 4, 8 and 10.