Schedule C: A New Era in Annual Reporting
The expanded reporting of direct and indirect service provider compensation on the new Schedule C represents perhaps the most substantive change to Form 5500 content.
The annual ritual of filing the Form 5500 is a familiar one for the hundreds of thousands of plan administrators charged with this responsibility. However, 2009 is a year of sweeping change for the Form 5500, and everyone involved is confronting new issues.
Expanded Reporting Requirements
The most substantive change to Form 5500 content is the expanded reporting of direct and indirect service provider compensation on the new Schedule C. The concept of indirect compensation is very different than in the past.
Benefits of the New Schedule C
- More Information for Plan Fiduciaries: By requiring the plan administrator to annually report on specific fee arrangements, the new Schedule C addresses the DOLs concern that some fiduciaries have difficulty getting information to understand and assess plan service provider fees
- More Public Information: The new Schedule C provides the DOL, plan fiduciaries, researchers and policymakers with more public data about fee arrangements and their costs
- More Enforcement Tools: The expanded Schedule C provides the DOL with new long-term enforcement tools and audit targeting capabilities
