1. Is there any special reporting for Common/Collective Trust and Pooled Separate Accounts if Schedule D is not filed by the DFE?

If you are completing Schedule D for a large pension plan that invests in a Common/Collective Trust (CCT) or Pooled Separate Account (PSA) that does not file its own Form 5500, there are special rules to follow in preparing the Schedule H. Refer to instructions to Schedule H - you may not report plan assets on line 1c(9) or 1c(10) for these entities on Schedule H if you show "000" as the plan number in Part I, line (c) on Schedule D.

2. How does a plan sponsor know if they need to attach Schedule D?

If the plan has investments in any of the direct filing entities (Common/Collective Trusts, Master Trust Investment Accounts, Pooled Separate Accounts, 103-12 Investment Entities) Schedule D must be attached to the plan sponsor's Form 5500. Failure to properly complete and file Schedule D can render the entire filing invalid.

Clues for Large Plan sponsors:
-- Schedule A, line 4 has value greater than $0.
-- Schedule H, lines 1c(9), (10), (11), or (12) have a value of greater than $0 at either the beginning or end of the plan year.

Clues for Small Plan sponsors:
-- Schedule A, line 4 has value greater than $0.

3. If we have been unable to determine whether a CCT or PSA is filing as a DFE, can we use "000" as a default plan number in completing Part I

This seems a very reasonable approach. Some DFEs are were late in collecting data to prepare their 1999 Form 5500 or may not have provided adequate information to plan sponsors, in spite of the DOL's regulations requiring them to notify plan sponsors or their status as a Form 5500 filer.

4. How does the plan sponsor complete Schedule D?

The plan sponsor never completes Part II of Schedule D. Part I should be completed by identifying each distinct direct filing entity in which the plan invests.

For example, if the plan has investments in an insurance contract that includes pooled separate accounts, each distinct pooled separate account must be reported on a separate line. Typically, each investment "option" under such a contract is in its own distinct pooled separate account. This is also true of most common/collective funds.

Only a direct filing entity that is filing its own Form 5500 completes Part II of Schedule D.

5. Should entries in Part I, line (e) be on a cash or accrual basis? Should they tie to entries on Schedules A or H?

Generally, these entries are on a cash basis. Information reported at line 4 of Schedule A should tie to entries for pooled separate accounts. Similarly, lines on Schedule H should tie to entries for master trust investment accounts, pooled separate accounts, common/collective trusts, and 103-12 investment entities.

6. If a Schedule D is completed to report a plan that has investments in a CCT, are any other attachments required?

The completion of Schedule D eliminates the attachments that were required in previous years for both common/collective trusts and pooled separate accounts. Also, you cannot meet the Schedule D requirement by using attachments. You must prepare Schedule D if it is required.