Department of Labor Issues Supplemental FAQs about the 2009 Form 5500 Schedule C Fee Disclosure Rules

On October 23, the U.S. Department of Labor (DOL) released its much-anticipated guidance on how to complete the new Schedule C to Form 5500. The new Schedule C must be used to report certain direct and indirect compensation received by service providers in connection with services provided to employee benefit plans, subject to the Employee Retirement Income Security Act of 1974, as amended (ERISA). As discussed in one of our previous LawFlashes, the new Schedule C is applicable for plan years beginning in calendar year 2009 and represents major changes from the old schedule.

This new guidance takes the form of additional answers to frequently asked questions (FAQs), which supplement both the instructions to Schedule C and a set of FAQs released by the DOL in July 2008 (the 2008 FAQs). In general, the new FAQs clarify a number of technical issues and provide additional support for answers given in the 2008 FAQs.

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