U.S. Department of Labor Form 5500 Schedule C Reporting

As you may recall, ERISA clients and investors often request information from you in order to complete their Form 5500. Attached is a memorandum that outlines the Form 5500 Schedule C reporting obligations that typically affect an investment manager with ERISA clients and/or investors. Note that this reporting obligation affects all investment managers with ERISA clients/investors regardless of the plan assets status of their funds. The attached memorandum includes model disclosures you may use to provide your ERISA clients/investors with Schedule C information; we find it is often simpler to provide all ERISA clients/investors with a uniform disclosure rather than responding to each individual request. If you have any questions or comments, please contact your attorney at Seward & Kissel LLP.