The Department of Labor’s Employee Benefits Security Administration published supplemental FAQs to provide further guidance in response to additional questions from plans and service providers on the requirements for reporting other compensation on the Schedule C of the Form 5500 Annual Return/Report of Employee Benefit Plan. Additional guidance pertaining to trustee and plan employee expense reimbursement was posted on the DOL’s website on October 14, 2010.
In response to questions where a plan trustee or employee receives reimbursement from the plan for expenses associated with travel and meals while attending educational conferences, trustees’ meetings, and business meetings, the Department has determined such expenses would be reportable on Schedule C.
Disbursements to a plan trustee or plan employee for transportation, hotels, meals, and similar expenses incurred by the plan trustee or plan employee for goods and services or other things of value furnished to him or her while engaged in official plan business and paid or reimbursed by the plan are reportable compensation for purposes of the Schedule C. In addition, cash gifts and personal expenses paid by the plan to or for the plan trustee, whether paid directly through prepayment or use of credit cards or other credit arrangement, and non-cash gifts are reportable compensation for purposes of the Schedule C.
In general, a plan trustee is included on Schedule C if total reportable compensation is $5,000 or more. A plan employee is included on Schedule C if the total reimbursed expenses combined with other compensation received by the employee from the plan are $25,000 or more during the plan year.
With regard to reporting plan employees’ salaries, total salaries (before taxes and other deductions) paid to employees should be used to determine whether an employee has received less than $25,000 during the plan year. The Schedule C instructions contain specific service codes for “plan employee” and “plan trustee” services.
Visit the DOL website at www.dol.gov/ebsa/faqs/faq-sch-C-supplement.html to read the “Supplemental FAQs About The 2009 Schedule C.” Further inquiries regarding these supplemental FAQs may be directed to EBSA’s Office of Regulations and Interpretations at 202-693-8523. We are also available to discuss your questions.