At the very end of 2008, we merged two small DB plans into the big receiving DB plan. This question has to do with how to complete the Schedule SSA of the receiving plan for 2008...when a participant has a deferred vested benefit in one of the transferee plans with a previously reported amount (monthly life annuity at nrd) and also has a deferred vested benefit in the receiving plan which has previously been reported. We know that on the 2008 Schedule SSA of the receiving plan, we'll use a Code "C" to show the participant was previously reported under another plan but will be receiving his/her benefits from the receiving plan instead. That also requires we show the previous sponsor's EIN and plan number.

A (the) question is whether we should also have a second entry for the participant on the 2008 Schedule SSA using a Code "B" with an entry in items (d),(e) and (f) of the Schedule SSA whereby we add the monthly life annuity amount at nrd from the transferring plan with the monthly life annuity amount from the receiving plan at nrd...as both plans express the benefit in the form of a life annuity (monthly) at nrd...and put that value in item (f). Unless I overlooked it, I don't see detailed guidance on this in the 2008 Form 5500 Instructions (Sch. SSA). While it seems the rational thing to do, I have some concern that the SSA will err by double counting the benefit and we have to deal with explaining that to a participant who seeks his/her benefit.

In the 2008 Schedule SSA Instructions, there is a section called "Revising Prior Report" that states "Use Schedule SSA to report revisions to pension information for a participant you reported on a previous Schedule SSA. This will ensure that SSA's records are correct. This is important since SSA provides Schedule SSA information that it has on file to participants when they file for Social Security Benefits. If this information is not up-to-date, the participant may contact the plan administrator to resolve the difference". Maybe this means we should do as noted in the second paragaph of this post.

I'd appreciate any thoughts/guidance...perhaps some of you have prior experience with a similar situation. Thanks.

Well you have to report the C amount (benefit preciously reports under other plan being transferred in) this year but what I'm unsure of is if this will actually mess up SSA records or will the participant just receive two notices from the same plan with different amounts. As a result, I might be inclined to do the C information this year and do the B information next year.

Since you are already reporting this participant with a code D in the transferor plan, you can accomplish everything you set out to do by reporting the participant with a code B (instead of a code C) in the transferee plan.