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Posted October 27, 2009

Additional guidance available for completing Schedule C of Form 5500

Additional guidance has been released by the U.S. Department of Labor’s Employee Benefits Security Administration (EBSA) to help plan administrators and service providers comply with the expanded requirements for reporting service provider fee and compensation information on the Form 5500 Annual Returns/Reports. These requirements apply for plan years beginning on or after January 1, 2009.

The EBSA has provided 25 frequently asked questions (FAQs) on the new Schedule C requirements, which include the reporting of:

- Gifts, entertainment and other non-monetary compensation;
- Compensation to hedge fund investment managers;
- "Look-through" investment funds;
- Mutual fund redemption fees; and
- ERISA fee recapture accounts.

Clarification is provided in these FAQs for service providers explaining that the transition relief also covers plan administrators and Form 5500 preparers who rely on those service providers for information needed to complete the Schedule C for the 2009 plan year. The EBSA explained the details about the transition relief in July 2008 and the new FAQs are available on EBSA’s web site.


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