5500 Reporting for Synthetic GICs

[austin3515]

I'm reading that there is not a lot of clarity on this topic regarding how to report these contracts on SChedule A, D and H.  Anyone have some insight.  I found this letter where someone who sounds like they know what they are talking about wrote the DOL to ask for guidance. 

https://www.dol.gov/sites/dolgov/files/EBSA/laws-and-regulations/rules-and-regulations/public-comments/1210-AB63/00105.pdf

My conclusion:

From what I have gathered , the insurance component is separate from the underlying investments in the CCT.  The insurance would go on A and H as an unallocated /general accounts contract and the CCT would go on the D.  How it is reported on the H depends on if it is a DFE (I’ll bet it is).  If a DFE you get to just report it as a CCT on the 5500.  If not a DFE technically you have to report each asset class separately (stocks, bonds, mutual funds).  

Do I have it right? Does anyone have something more substantial written up?