DOL Issues Supplemental FAQs About the 2009 Schedule C

On October 23, 2009, the Department of Labor’s Employee Benefits Security Administration (“DOL”) published on its website much anticipated supplemental “FAQs” addressing the 2009 Form 5500 Schedule C reporting rules (available at http://www.dol.gov/ebsa/faqs/faq-sch-C-supplement.html) (“2009 FAQs”). The new FAQs supplement FAQs issued by DOL in July 2008 (“2008 FAQs”) and the final amendments to regulations, forms and instructions governing the Schedule C, which were published in November 2007. We discuss the new guidance in the attached memo.