Lynda Hill Posted April 17 Posted April 17 I have a 401k plan where the investments were ppt directed until October 2024. The plan switched to "pooled" account and is now owner only. Do I include the 5500 codes (2G) for ppt directed on the 5500SF since the plan was ppt directed for a portion of the year?
Peter Gulia Posted April 17 Posted April 17 The Form 5500 Instructions state: Page 1: “Each Form 5500 must accurately reflect the characteristics and operations that applied during the reporting year of the plan or arrangement.” Page 19: “In the boxes for line 8a and 8b, as appropriate, enter all applicable two-character plan characteristics codes that applied during the reporting year[.]” Page 36 [part V line 8]: “Enter all applicable pension plan characteristics codes that applied during the reporting year[.]” https://www.dol.gov/sites/dolgov/files/ebsa/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500/2024-instructions.pdf While the word during has meanings that depend on the context, the sentences quoted above do not mention the beginning or end of a year. With its lawyer's advice, the plan’s administrator might consider reporting every code that describes the plan on any day of the reported-on year. But an edit in the Form 5500 software, especially if it’s from the Labor department rather than the software designer, might point in another direction. This is not advice to anyone. Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
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