EBSA Issues More Guidance on Form 5500 Schedule C

The Department of Labor's Employee Benefits Security Administration (EBSA) has issued additional guidance in response to questions from plans and service providers on the requirements for reporting service provider fees and other compensation on Schedule C of Form 5500.

EBSA noted that the expanded requirements apply to reporting for plan years beginning on or after January 1, 2009.

The guidance is provided in the form of 25 frequently-asked questions (FAQs), and topics covered include:

  • 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.

The guidance also provides clarification regarding the 2009 plan year transition relief for service providers by 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.  The details about the transition relief were explained in an earlier set of FAQs released in July 2008 (see “EBSA Delivers Schedule C FAQs“).

The FAQs are located here .