"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?"

"The plan charges a fee to terminated participants who leave funds in the plan. $100 per ppt per year. The recordkeeper also pays revenue sharing to the TPA. The Revenue sharing now equals or exceeds the TPA fees, and the $100 per ppt per year charge is being put in a 'forfeiture' account, and the client is being told to offset required match contribution by the balance in the forfeiture.... This fee doesn't seem to qualify as a 'forfeiture' as that term is defined. So, what can be done with these amounts?"