Do we need a Schedule B?

There are a lot of facts involved here, so please bear with me.

We took over this client in 2016, when they had directed trustee XYZ Bank.  The Plan is a DB plan.

Back in 2014, the ABC Bank was the directed trustee.  ABC was an affiliate of mega-vendor DEF.  

In 2014 the client moved from Mega-vendor to local TPA and changed the trustee to XYZ Bank.

In 2017 client terminated the plan, distributed all assets, issued 1099-Rs, filed a final 5500, etc.: they closed out the plan.  

Now it is 2018 and we have learned that back in 2014 somebody dropped the ball and left about $900 at ABC Bank.  Nobody seemed to notice it until now.  That $900 belongs to about 12 different participants.  

We are cleaning everything up now.  My question is whether we need a Schedule SB for the 2018 Form 5500.  

Do you need a 5500 for the 2018 PY?  I don't know, but there does not seem to be any requirement for the Schedule SB.

It depends on how the Plan Administrator chooses amongst its options. First, you typed XYZ when you meant ABC.  No matter.  The key issue is whether the Plan Administrator treats the plan as terminated on the original termination date or whether, pursuant to Rev. Rul. 89-87 the original termination date is lost. Obviously a job for ERISA counsel here, but I would be surprised if the termination date didn't hold.  If so, no SB for 2018.

Thanks Mike. I corrected the typo.  Also, I think we need to talk to the PBGC.  

I don't see how the PBGC would care.  It was a standard termination, right?  The implication is that without this $900 the plan paid everybody out what they were entitled to, right?  So this $900 effectively were excess assets to be allocated amongst the 12 participants, right? If right, right, right then the PBGC won't care because they NEVER care about the allocation of excess assets.

Mike,

As usual you are correct.