2009 Instructions For Schedule C (Form 5500) Service Provider Information


Requirement under General Instructions to Form 5500. The
2009 Instructions for Schedule C
EBSA does not issue EINs.
Do not list the PBGC or the IRS on Schedule C as service
(Form 5500)
Service Provider Information
Either the cash or accrual basis may be used for the
recognition of transactions reported on the Schedule C as long
as you use one method consistently.
General Instructions
If service provider compensation is reported on a Schedule
Who Must File
C filed as apart of a Form 5500 filed for a MITIA or a 103-12 IE,
do not report the same compensation again on the Schedule C
Schedule C (Form 5500) must be attached to a Form 5500 filed
filed for the plans that participate in the MTIA or 103-12 IE.
for a large pension or welfare benefit plan, a MTIA, a 103-12 IE,
or a GIA to report certain information concerning service
Specific Instructions
providers. Remember to check the Schedule C box on the Form
Part I - Service Provider Information You must enter the
5500 (Part II, line 10b(4)) if a Schedule C is attached to the
information required for each person who rendered services to
Form 5500.
or had transactions with the plan and who received $5,000 or
Part I of the Schedule C must be completed to report
more in total direct or indirect compensation in connection with
persons who rendered services to or who had transactions with
services rendered to the plan or the person’s position with the
the plan (or with the DFE in the case of a Schedule C filed by a
plan during the plan year.
DFE) during the reporting year if the person received, directly or
Example. A plan had service providers, A, B, C, and D,
indirectly, $5,000 or more in reportable compensation in
who received $12,000, $6,000, $4,500, and $430, respectively,
connection with services rendered or their position with the plan
in direct and indirect compensation from the plan. Service
or DFE, except:
providers A and B must be identified separately by name, EIN,
1. Employees of the plan whose only compensation in
etc. As service providers C and D each received less than
relation to the plan was less than $25,000 for the plan year;
$5,000, they do not need to be reported on the Schedule C.
2. Employees of the plan sponsor or other business entity
For Schedule C purposes, reportable compensation includes
where the plan sponsor or business entity is reported on the
money and any other thing of value (for example, gifts, awards,
Schedule C as a service provider, provided the employee did
trips) received by a person, directly or indirectly, from the plan
not separately receive reportable direct or indirect
(including fees charged as a percentage of assets and
compensation in relation to the plan;
deducted from investment returns) in connection with services
3. Persons whose only compensation in relation to the plan
rendered to the plan, or the person’s position with the plan. The
consists of insurance fees and commissions listed in a
term “person” for this purpose includes individuals, trades and
Schedule A filed for the plan; and
businesses (whether incorporated or unincorporated). See
4. Payments made directly by the plan sponsor that are not
ERISA section 3(9).
reimbursed by the plan.
Direct Compensation: Payments made directly by the plan
for services rendered to the plan or because of a person’s
Only line 1 of Part I of the Schedule C must be completed for
position with the plan are reportable as direct compensation.
persons who received only “eligible indirect compensation” as
Direct payments by the plan would include, for example, direct
defined below.
payments by the plan out of a plan account, charges to plan
Part II of the Schedule C must be completed to report
forfeiture accounts and fee recapture accounts, charges to a
service providers who fail or refuse to provide information
plan’s trust account before allocations are made to individual
necessary to complete Part I of this Schedule.
participant accounts, and direct charges to plan participant
Part III of the Schedule C must be completed to report a
individual accounts. Payments made by the plan sponsor,
termination in the appointment of an accountant or enrolled
which are not reimbursed by the plan, are not subject to
actuary during the 2009 plan year.
Schedule C reporting requirements even if the sponsor is
paying for services rendered to the plan.
For plans, GIAs, MTIAs, and 103-12 IEs required to file Part
I of Schedule C, commissions and fees listed on the Schedule
Indirect Compensation: Compensation received from
A are not required to be reported again on Schedule C. The
sources other than directly from the plan or plan sponsor is
amount of the compensation that must be reported on Schedule
reportable on Schedule C as indirect compensation from the
A must, however, be taken into account in determining whether
plan if the compensation was received in connection with
the service provider’s direct or indirect compensation in relation
services rendered to the plan during the plan year or the
to the plan or DFE is $5,000 or more and, thus, requiring the
person’s position with the plan. For this purpose, compensation
compensation not listed on the Schedule A to be reported on
is considered to have been received in connection with services
the Schedule C. See “FAQs About the 2009 Form 5500
rendered to the plan or the person’s position with the plan if the
Schedule C” available on the EBSA website at
person’s eligibility for a payment or the amount of the payment
is based, in whole or in part, on services that were rendered to
the plan or on a transaction or series of transactions with the
Health and welfare plans that meet the conditions of the
plan. Indirect compensation would not include compensation
limited exemption at 2520.104-44 or Technical Release
that would have been received had the service not been
92-01 are not required to complete and file a Schedule
rendered or the transaction had not taken place and that cannot
be reasonably allocated to the services performed or
Lines A, B, C, and D. This information must be the same as
transaction(s) with the plan.
reported in Part II of the Form 5500 to which this Schedule C is
Persons that provide investment management,
recordkeeping, claims processing, participant communication,
Do not use a social security number in line D in lieu of an
brokerage, and other services to the plan as part of an
EIN. The Schedule C and its attachments are open to public
investment contract or transaction are considered to be
inspection, and the contents are public information subject to
providing services to the plan for purposes of Schedule C
publication on the Internet. Because of privacy concerns, the
reporting and would be required to be identified in Part I if they
inclusion of a social security number on this Schedule C or any
received $5,000 or more in reportable compensation for
of its attachments may result in the rejection of the filing.
providing those services.
You can apply for an EIN from the IRS online, by telephone,
Examples of reportable indirect compensation include fees
by fax, or by mail depending on how soon you need to use the
and expense reimbursement payments received by a person
EIN. For more information, see Section 3: Electronic Filing
from mutual funds, bank commingled trusts, insurance
Instructions for Schedule C (Form 5500)


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