Faqs About Reporting Delinquent Participant Contributions On The Form 5500 - U.s. Department Of Labor Page 3
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schedules and that the IQPA’s report covers the delinquent contributions even though they are
no longer required to be included on Line 4d or on the Schedule G.
What disclosure will satisfy the requirement that the information on Line 4a must
be treated by plans subject to the audit requirement as part of the supplemental
schedules for purposes of the IQPA report and opinion?
The requirement may be satisfied by including an attachment in the Form 5500 report labeled
"Line 4a -- Schedule of Delinquent Participant Contributions" that sets forth the information
on Line 4a regarding total aggregate delinquency for the plan year and the subtotal that
constitutes nonexempt prohibited transactions. As noted above, in calculating this subtotal,
plan administrators and IQPAs should understand that all delinquent participant contributions
required to be reported on Line 4a are nonexempt prohibited transactions unless the
delinquency has been corrected under the VFCP and the conditions of PTE 2002-51 have
been satisfied. Further, the IQPA’s report must include a statement on whether Line 4a and
the scheduled information are presented fairly in all material respects in relation to the basic
financial statements taken as a whole.
Has the Department developed a model for the Line 4a Schedule of Delinquent
Participant Contributions that plan administrators and IQPAs can use?
Yes. The schedule could use the format set forth below or a similar format on the same size
paper as the Form 5500.
2003 Form 5500 Line 4a - Schedule of Delinquent Participant Contributions
Participant Contributions transferred Late to
Total that Constitute Nonexempt Prohibited
Plan
transactions
Although not required, plan administrators may want to include information regarding the
extent to which the delinquencies have been corrected under the VFCP for which the
conditions of PTE 2002-51 have been satisfied, delinquencies otherwise corrected, and
uncorrected delinquencies. In those cases, the schedule could use the format set forth below:
2003 Form 5500 Line 4a - Schedule of Delinquent Participant Contributions
Participant
Total that Constitute Nonexempt Prohibited transactions
Total Fully
Contributions
Corrected Under
Contributions Not
Contributions
Contributions
transferred Late
VFCP and PTE
Corrected
Corrected
Pending
to Plan
2002-51
Outside VFCP
Correction in
VFCP
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