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Legal Update

Schedule C of the 2009 Form 5500—Checklist for Plan Administrators

12 March 2010
Mayer Brown Legal Update

The new Schedule C to the Form 5500, which plan administrators and certain other “direct filing entities” must use beginning with the 2009 reporting year,1 significantly expands the scope of compensation that must be reported. For example, under the new rules, plan administrators may be required to report:

  • The value of gifts, entertainment, conferences, and other non-monetary benefits received by a plan sponsor’s employees from plan service providers
  • Float revenue received by the plan’s custodian
  • The value of soft dollar services received by plan investment managers
  • 12b-1 fees and shareholder servicing fees paid to recordkeepers, custodians or other parties in connection with the investment of plan assets in mutual funds
  • Fees paid to placement agents and solicitors in connection with plan investments
  • Certain fees paid by mutual funds and private investment funds to their service providers

The complexity and broad scope of the information that must now be gathered, particularly for large plan sponsors, is likely to make this process onerous and time-consuming, and may require recordkeeping, policy and procedural changes. Accordingly, plan administrators should not delay in getting the process underway. This Schedule C checklist and companion newsletter are intended to help plan administrators evaluate how the changes will affect their reporting obligations and establish a process to gather the information they will need for the 2009 report.

Even plan administrators who outsource the task of preparing the Form 5500 are encouraged to review these materials and discuss them with their vendors, given the significant amount of new information that will need to be gathered from new sources and the potential liability retained by plan administrators who fail to timely file a complete Form 5500.

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1. The US Department of Labor  (DOL) published the revised Form 5500, as well as accompanying regulations, on November 16, 2007. On July 14, 2008 and October 23, 2009, the DOL issued “FAQs [Frequently Asked Questions] About The 2009 Form 5500 Schedule C” and “Supplemental FAQs,” respectively, clarifying certain aspects of the 2009 Form 5500 Schedule C (

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