Special Terminal Report Instructions For Abandoned Plans

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DOL regulation 29 CFR 2578.1 provides a method to facilitate the termination of, and distribution of benefits from, individual account pension plans that have been abandoned by their sponsoring employers. The qualified termination administrator (QTA) of each plan terminated under 29 CFR 2578.1 must file the Special Terminal Report for Abandoned Plans (STRAP) in accordance with 29 CFR 2520.103-13.

General Instructions

Follow these instructions to satisfy the requirements set forth in 29 CFR 2520.103-13.

Who Must File

The QTA of each plan terminated pursuant to 29 CFR 2578.1 must file the STRAP.

How to File

File the STRAP as an attachment to the Final Notice. Under 29 CFR 2578.1(d)(2)(ix), the QTA of each plan terminated under 29 CFR 2578.1 must send a Final Notice to EBSA Office of Enforcement.

Where to File

By mail to: Abandoned Plan Coordinator, Office of Enforcement, Employee Benefits Security Administration, U.S. Department of Labor, 200 Constitution Avenue, NW, Suite 600, Washington, DC, 20210.

By Email to: qtanotices@dol.gov.  To submit the STRAP by email, see Additional Instructions for Email Filers below.

Do not file the STRAP at any address listed in Section 3 of Form 5500 instructions.

Specific Instructions

A QTA has two options under these instructions. File Form 5500 and Schedule I (and certain non-standard schedules). Or, file Form 5500 and Schedule QTA.  Either option satisfies STRAP requirements.

Option One

Complete Form 5500 and Schedule I in accordance with these instructions.

Form 5500

Part I. Check box A(4) and enter “Q” in the space provided and check box B(3).  Check box C, if applicable.

Part II. Complete lines 1a, 2a, 5, and 10b. Complete lines 1b, 1c, 2b, 2c, 3a, 3b, and 3c based on the best available information, but if the requested information is not known, then leave blank. The QTA should be identified as the preparer for purposes of lines 5a, 5b, and 5c. A representative authorized to sign on behalf of the QTA must sign and date Form 5500 in the space designated for the employer/plan sponsor/DFE. No other signatures are required.

Schedule I

Complete lines A, C, D, 1a, 2e, 2h, and 3. Complete lines B and D based on the best available information, but if the requested information is not known, then leave blank.

Line 1a. Enter in column (b) the total assets of the plan as of the date the plan was deemed terminated under 29 CFR 2578.1(c). This amount should reflect total assets of the plan prior to any reduction for termination expenses and distributions.

Line 2e. Enter total distributions pursuant to 29 CFR 2578.1(d)(2)(vii), including distributions in accordance with 29 CFR 2550.404a-3.  You also must attach a schedule indicating whether any distributions were made on behalf of missing or non-responsive participants or beneficiaries. For this purpose, a person that fails to make a benefit election within 30 days from the furnishing of the notice referred to in 29 CFR 2578.1(d)(2)(vii)(B) is considered a missing or non-responsive person. The schedule required to be attached must be clearly labeled “Schedule I, line 2e — Statement of Distributions on Behalf of Missing or Non-responsive Persons.”

Line 2h. Enter total expenses paid by the plan in accordance with 29 CFR 2578.1 and attach a schedule identifying each service provider (including the QTA) and amount received, itemized by expense. This schedule must be clearly labeled “Schedule I, line 2h — Schedule of Expenses.” The schedule must indicate the relationship, if any, between each service provider and the QTA, e.g., “subsidiary” or “none.” Use the following categories to itemize expenses on the schedule:

1. Plan administration

2. Recordkeeping

3. Determining abandonment

4. Department of Labor notifications & STRAP

5. Calculating benefits (including valuation services, e.g., appraisals)

6. Searching for missing participants

7. Benefit distributions (including participant notification and IRS documents)

8. Other (specify)

Any expenses not described in 1 through 7 must be listed on the schedule only if such expense is greater than $49. A brief description of each such expense must be included on the schedule, e.g., “Other: legal services.” Do not describe such expenses only as “Other.” All expenses paid by the QTA in accordance with 29 CFR 2578.1 must be included in the total on line 2(h) whether or not they are listed on the schedule.

Lines 3a through 3g. Check “Yes” or “No” on each line to report whether the plan held any assets in the listed categories. If “Yes” is checked on any line, enter the fair market value in the amount column for that line and attach a schedule describing the method of valuation for each such category. The schedule required to be attached must be clearly labeled “Schedule I, lines 3a through 3g — Schedule of Method of Valuation.”

If the plan held assets with no readily ascertainable fair market value and the assets are not described in lines 3a through 3g, attach a schedule identifying each such asset by category. The schedule must include the fair market value of those assets and the method of valuation, by category. The schedule required to be attached must be clearly labeled “Schedule I — Schedule of Assets Not Listed in Lines 3a through 3g.”

Option Two

Complete Form 5500 and Schedule QTA in accordance with these instructions.

Form 5500

Part I. Check box A(4) and enter “Q” in the space provided and check box B(3).  Check box C, if applicable.

Part II. Complete lines 1a, 2a, and 5. Complete lines 1b, 1c, 2b, 2c, 3a, 3b, and 3c based on the best available information, but if the requested information is not known, then leave blank. The QTA should be identified as the preparer for purposes of lines 5a, 5b, and 5c. A representative authorized to sign on behalf of the QTA must sign and date Form 5500 in the space designated for the employer/plan sponsor/DFE. No other signatures are required.

Schedule QTA

Lines A, B, C, D, E, and F. This information should be the same as reported in Part II of Form 5500 to which Schedule QTA is attached.

Line G. Enter the total assets of the plan as of the date the plan was deemed terminated under 29 CFR 2578.1(c). This amount should reflect total assets of the plan prior to any reduction for termination expenses and distributions to participants and beneficiaries.

Line H. Enter the total expenses paid by the QTA in accordance with 29 CFR 2578.1. You also must complete Part II of Schedule QTA.

Line I. Enter the total distributions made pursuant to 29 CFR 2578.1(d)(2)(vii), including distributions in accordance with 29 CFR 2550.404a-3.

Line J. Check “Yes” or “No” to indicate whether any distributions were made on behalf of missing or non-responsive participants or beneficiaries. For this purpose, a person that fails to make a benefit election within 30 days from the furnishing of the notice referred to in 29 CFR 2578.1(d)(2)(vii)(B) is considered missing or non-responsive.

Line K. Check “Yes” or “No” to indicate whether the plan held assets with no readily ascertainable fair market value. If “Yes,” the QTA must also complete Part III of Schedule QTA.  Examples of assets that may not have a readily determinable value on an established market (e.g., NYSE, AMEX, over the counter, etc.) include real estate, non-publicly traded securities, shares in a limited partnership, and collectibles.

Part II. You should have entered total expenses on line H of Part I. Identify in Part II each service provider (including the QTA) and amount received, itemized by expense. The QTA must indicate the relationship, if any, between each service provider and the QTA, e.g., “subsidiary” or “none.” The QTA must provide a general description of each expense, selecting from the following categories:

1. Plan administration

2. Recordkeeping

3. Determining abandonment

4. Department of Labor notifications & STRAP

5. Calculating benefits (including valuation services, e.g., appraisals)

6. Searching for missing participants

7. Benefit distributions (including participant notification and IRS documents)

8. Other (specify)

Any expenses not described in 1 through 7 must be listed only if such expense is greater than $49. A brief description of each such expense must be included on the schedule, e.g., “Other: legal services.” Do not describe such expenses only as “Other.” All expenses paid by the QTA in accordance with 29 CFR 2578.1 must be included in the total on line H of Part I whether or not they are listed in Part II.

Part III. If the plan held assets with no readily ascertainable fair market value, check “Yes” or “No.” For each category that is checked “Yes,” enter the current value and state the valuation method for each such asset.