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May 9 2012

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DOL Sending Emails to Form 5500 Filers About Schedule C Requirements

The Department of Labor is sending emails to Form 5500 filers if they are large employee benefit plans that have not included a Schedule C, Scott C. Albert, chief of the reporting and compliance division at DOL’s Employee Benefits Security Administration, said May 8.

DOL is concerned that plan administrators and fiduciaries are unaware of the fees and expenses that are supposed to be reported on Schedule C, Albert said. Plan sponsors are required to report on Schedule C each service provider that received $5,000 or more in direct or indirect compensation from a plan. There are very few large plans that do not require a Schedule C, primarily because of investments in mutual funds, Albert said. As a result, DOL is looking at forms filed by large plans that are missing the Schedule C, Albert said. In addition, DOL is communicating with many third-party administrators that are unaware of these fees and expenses and how they relate to Schedule C, he said.

If you have any questions regarding requirements to report direct and indirect compensation, or any other employee benefits matter, please feel free to contact us.