ASPPA Calls for Enhancements to Schedule C and Its Instructions
Revisions Would Benefit DOL and Filers; Improves Consistency and Reduces Confusion
ARLINGTON, VA, (July 29, 2013) – The following is a statement from Craig P. Hoffman, General Counsel and
Director of Regulatory Affairs of the American Society of Pension Professionals & Actuaries (ASPPA), to the
United States Department of the Labor (“DOL”) requesting modification of Schedule C of Form 5500 to better
apply new disclosure requirements while improving consistency in the reporting of indirect compensation:
“ASPPA appreciates the DOL’s continued engagement with the public regarding proposals to simplify and
improve reporting procedures for retirement plans covered under the Employee Retirement Income Security Act
of 1974 (“ERISA”). Beginning with 2009 plan year filings, Form 5500 series reports, as part of ERISA’s overall
reporting and disclosure framework, have been required to provide information on Schedule C intended to
increase transparency regarding compensation and expenses paid by such plans. After three years of experience
with the current Schedule C, ASPPA believes certain improvements can be made.
First, ASPPA encourages a shift in reporting in Part I to focus solely on information about service providers that
received indirect compensation and eliminate the distinction between indirect compensation that is ‘eligible’ for
simplified reporting and indirect compensation that is not ‘eligible’. The term ‘eligible’ has been inconsistently
interpreted by Form 5500 preparers, which results in less useful data being collected by the DOL.
Second, ASPPA recommends that the DOL provide that the information required to be reported about service
providers who receive $5,000 or more of direct compensation be streamlined to the amount of direct
compensation, the service codes associated with such compensation, and whether the service provider also
received any indirect compensation from the plan. Reducing the reporting of direct and indirect compensation in
this manner allows for a simplification of service codes because there would no longer be different types of
indirect compensation. ASPPA’s proposed Schedule C, included with our comment letter, also contains a
modified listing of service codes.
Finally, ASPPA recommends that the DOL update instructions to Part III of Schedule C to provide that the
termination of a plan’s accountant or enrolled actuary should be reported on Schedule C for the plan year in
which the change is first reflected on either the Accountant’s Opinion or the Actuarial Schedule (SB or MB),
instead of the current requirement that the termination be reported during the plan year in which the termination
actually occurred.
Adoption of these modifications will assist both the DOL and plan fiduciaries by eliminating confusion about the
reporting of the indirect compensation of service providers, improving reporting consistency and enhancing the
quality of data collected by the DOL about large plans.”
For more detail on ASPPA’s request to the DOL, read our comment letter here.
About ASPPA:
The American Society of Pension Professionals & Actuaries (ASPPA) is a national organization of more than
16,000 retirement plan and benefits professionals that serves as the educator, voice and advocate for the
employer-based retirement system. ASPPA members are administrators, actuaries, advisors, attorneys,
accountants and other financial services professionals who provide consulting and administrative services for
qualified retirement plans. For the latest news, visit www.asppanews.org.
Media Contact:
Ryan Shucard
Media Relations Manager
(703) 516-9300 Ext. 130
rshucard@asppa.org
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4245 North Fairfax Drive, Suite 750 · Arlington, VA 22203-1648
P. 703.516.9300 · F. 703.516.9308 · www.asppa.org
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