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Posted

A Form 5500 Schedule H or I question asks: “Was this plan covered by a fidelity bond?” The form has boxes for Yes or No, and a line to state an amount.

How does one answer this question if a fiduciary obtained the insurance before the administrator signed the Form 5500 but after the reported-on plan year ended? (Assume the fiduciary does not buy retroactive coverage.)

Does the past-tense “was” refer to any time in the past?

Or does “was” in context suggest the question refers, somehow, to the reported-on plan year?

How does one answer the question if the fiduciary obtained the insurance during the reported-on plan year (so the plan was uninsured for some portion of the year)?

Am I right in guessing the usual software restrains a user from answering both Yes and No?

For the line that calls for a coverage amount, does one report the amount that applied as at the beginning of, or the end of, the reported-on year? Or is it the highest coverage amount on any day in the plan year?

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

Posted

Bri, RatherBeGolfing, and Paul I, thank you for your swift and nice help. If you count your pro bono volunteer hours, this counts; you’ve aided my volunteer work for a charitable organization.

Bri, thank you for correcting my too-hasty reading. I read Schedule H’s line 4e on page 4 without seeing a lead on page 3. That “During the plan year:” phrase resolve almost all the reporting questions (and the remaining bit is trivial).

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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