Is the DFVC Program applicable to filings made by direct filing entities (DFEs) (i.e., master trusts, pooled separate accounts, common/collective trusts, 103-12 IEs, and group insurance arrangements)?
The DFVC Program is not applicable to DFE filings made for master trusts, pooled separate accounts, common/collective trusts and 103-12 IEs. The Form 5500 filed by these DFEs is an integral part of the annual report of the participating employee benefit plans. If a Form 5500 was timely filed for the participating employee benefit plans, a failure to timely file a DFE Form 5500 for these entities may cause the plans annual report to be incomplete or inaccurate, but it does not result in the plan being a late or non-filer. The plans Form 5500, however, may be subject to rejection for being incomplete or inaccurate, and, if rejected, a plan administrator who failed to correct the problem would be subject to penalty assessments by theDepartment. A Form 5500 filed for a group insurance arrangement (GIA) under the Departments regulations relieves the plan administrators of the individual plans participating in the GIA from the requirement to file a separate Form 5500 for each plan. The Depar
Related Questions
- Is the DFVC Program applicable to filings made by direct filing entities (DFEs) (i.e., master trusts, pooled separate accounts, common/collective trusts, 103-12 IEs, and group insurance arrangements)?
- Is the DFVCP applicable to filings made by direct filing entities (DFEs) (i.e., master trusts, pooled separate accounts, common/collective trusts, 103-12 IEs, and group insurance arrangements)?
- If a filing has been made under the DFVC Program, will the plan administrator be liable for any other Department of Labor annual reporting civil penalties?
