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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.
Follow these instructions to satisfy the requirements set forth in 29
CFR 2520.103-13.
The QTA of each plan terminated pursuant to 29 CFR 2578.1 must file the
STRAP.
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.
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.
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.
Complete Form 5500 and Schedule I in accordance with these
instructions.
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.
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:
-
Plan administration
-
Recordkeeping
-
Determining abandonment
-
Department of Labor notifications & STRAP
-
Calculating benefits (including valuation services, e.g.,
appraisals)
-
Searching for missing participants
-
Benefit distributions (including participant notification and IRS
documents)
-
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.”
Complete Form 5500
and Schedule QTA in accordance with these
instructions.
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.
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:
-
Plan administration
-
Recordkeeping
-
Determining abandonment
-
Department of Labor notifications & STRAP
-
Calculating benefits (including valuation services, e.g.,
appraisals)
-
Searching for missing participants
-
Benefit distributions (including participant notification and IRS
documents)
-
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.
You may submit the STRAP as an electronic attachment accompanying the
Final Notice only in the following manner. First, you must properly
complete the Form 5500 and Schedule I (or just Form 5500 under Option
Two) using the latest available official government produced, hand-print
forms or the latest available machine-print forms produced with EFAST-approved
software. Second, scan or convert the completed Form 5500 and Schedule I
(or just Form 5500 under Option Two) into one Adobe Portable Document
Format (PDF) file. Attach the PDF file and submit with the Final
Notice to
the email address listed above. If applicable, Schedule QTA and other
attachments may be submitted with the email using one of the following
allowable attachment types:
-
ASCII character (text) format
-
Microsoft Word 6.0 document format
-
Corel WordPerfect 6.0 document format
-
Adobe 3.0 Portable Document Format (PDF)
-
Hypertext-Markup Language (HTML) format
-
Microsoft Excel 5.0 format
-
Lotus 1-2-3 3.0 format
You can order the official government produced, hand-print forms by
calling 1.800.TAX-FORM (1.800.829.3676). For those interested in filing on
machine print forms, see www.efast.dol.gov for a list of EFAST approved
software vendors.
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