Clarification of Form 5500 Reporting for Delinquent Deposits of Participant Contributions (Posted May 15, 2005) Technical Tip 53: The Following question and answer are from the DOL/EBSA website: Must all delinquent participant contributions be reported on Line 4a of Schedule I (for small plans) or Schedule H(large plans) of the Form 5500 or only those that have not been corrected during the year? DOL Response: Schedule H and Schedule I filers must report all delinquent participant contributions for the plan year on Line 4a regardless of whether they have been corrected under the VFCP and the conditions of PTE 2002-51 have been satisfied. Comment by the RLR&C ERISA attorneys: VFCP is the Department of Labor Voluntary Fiduciary Correction Program which permits correction of certain prohibited transactions and PTE 2002-51 is the IRS exemption from excise tax for prohibited loans corrected under the VFCP program which otherwise qualify for the exemption. View all Tips © 2009 Reish Luftman Reicher & Cohen, a Professional Corporation Important notice: Answers are provided as general guidance on the subjects covered in the question and are not provided as legal advice to the questioner's situation. Any legal issues should be reviewed by your legal counsel to apply the law to the particular facts of your situation.