SUPPLEMENTAL SCHEDULES FOR © 2010 … SCHEDULES FOR © 2010 WithumSmith+Brown, PC REPORTABLE...

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The information contained herein is not necessarily all inclusive, does not constitute legal or any other advice, and should not be relied upon without first consulting with appropriate qualified professionals for your plan’s individual facts and circumstances. © 2010 WithumSmith+Brown, PC SUPPLEMENTAL SCHEDULES FOR REPORTABLE TRANSACTIONS When is a supplemental schedule of reportable transactions (line 4j) required to be included with an employee benefit plan financial statements and how are reportable transactions determined? Here is a general summary of how to deal with this issue: Exception to Reporting - Participant directed employee benefit plan transactions should not be treated as reportable transactions. Accordingly, participant directed employee benefit plans typically are generally not required to have a supplemental schedule of reportable transactions. The 5% Threshold - Transactions subject to reporting are based on a 5% threshold. To measure the 5% threshold, the denominator should be based on value of plan assets as of the beginning of the year, or if the plan’s initial year, as of the end of the initial year. Any of the following other transactions should be included on the supplemental schedule as a reportable transaction: A single transaction within the plan year over the 5% threshold. The aggregate amount of any series of transactions with the same person involving property, other than securities , where the aggregate amount is over the 5% threshold. Any transaction involving a particular security , if within the plan year, the aggregate amount of transactions with that security is over the 5% threshold. If a person had a single securities transaction within the plan year of over 5%, all other securities transactions with that person during the plan year. (Continued on next page ) WITHUMSMITH+BROWN EMPLOYEE BENEFIT PLAN SERVICES GROUP Helping Retirement Plans “BE IN A POSITION OF STRENGTH”. by David R. Dacey, CPA, Partner, Practice Leader, WS+B Employee Benefit Plan Services Group

Transcript of SUPPLEMENTAL SCHEDULES FOR © 2010 … SCHEDULES FOR © 2010 WithumSmith+Brown, PC REPORTABLE...

The information contained herein is not necessarily all inclusive, does not constitute legal or any other advice, and should not be relied upon without first consulting with appropriate qualified professionals for your plan’s individual facts and circumstances.

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SUPPLEMENTAL SCHEDULES FOR REPORTABLE TRANSACTIONS

When is a supplemental schedule of reportable transactions (line 4j) required to be included with an employee benefit plan financial statements and how are reportable transactions determined? Here is a general summary of how to deal with this issue:

• Exception to Reporting - Participant directed employee benefit plan transactions should not be treated as reportable transactions. Accordingly, participant directed employee benefit plans typically are generally not required to have a supplemental schedule of reportable transactions.

• The 5% Threshold - Transactions subject to reporting are based on a 5% threshold. To measure the 5% threshold, the denominator should be based on value of plan assets as of the beginning of the year, or if the plan’s initial year, as of the end of the initial year.

• Any of the following other transactions should be included on the supplemental schedule as a reportable transaction:

• A single transaction within the plan year over the 5% threshold.

• The aggregate amount of any series of transactions with the same person involving property, other than securities, where the aggregate amount is over the 5% threshold.

• Any transaction involving a particular security, if within the plan year, the aggregate amount of transactions with that security is over the 5% threshold.

• If a person had a single securities transaction within the plan year of over 5%, all other securities transactions with that person during the plan year.

(Continued on next page )

WITHUMSMITH+BROWN EMPLOYEE BENEFIT PLAN SERVICES GROUP Helping Retirement Plans “BE IN A POSITION OF STRENGTH”.

by David R. Dacey, CPA, Partner, Practice Leader, WS+B Employee Benefit Plan Services Group

The information contained herein is not necessarily all inclusive, does not constitute legal or any other advice, and should not be relied upon without first consulting with appropriate qualified professionals for your plan’s individual facts and circumstances.

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SUPPLEMENTAL SCHEDULES FOR REPORTABLE TRANSACTIONS (CONTINUED)

• Master Trust Rules - If all assets are in a master trust, the supplemental schedule is not required. If only some of the plan assets are in a master trust, the denominator should be determined by excluding the assets of the master trust.

• A pooled separate account (PSA) or a common collective trust (CCT) is deemed to be a particular security for purposes of this evaluation. Individual CCT or PSA transactions are not included.

• Individual registered investment company transactions are not included.

NEED MORE INFORMATION? If you need more information regarding this or any other topic affecting your retirement plan, visit our Withum ERISA Knowledge Corner online or contact us at [email protected] to arrange a free consultation today.