Several of our large plans transferred their entire plan assets from Fidelity Investments to Manulife Financial during 2002. Is a custodian to custodian transfer considered when determining the 5% figure for line 4j?

The plan basically switched recordkeepers along with asset holder, are we required to report the transactions that were done to accomplish this?

A custodian to custodian transfer would not trigger reporting as a 5% transaction. However, if Fidelity and Manulife offer different investment vehicles (and they probably do), the disposition of the Fidelity vehicles and the acquisition of the Manulife vehicles would be reportable. Unless these are all participant directed investments....

Even the investments are generally participant directed wouldn't the transfer from Fidelity to Manulife be a reportable transaction, simply because that transaction was not participant directed?