Phil Pavarini is a licensed insurance producer and is compensated when a bond is placed through this site. This page is general information, not legal, tax or fiduciary advice, and it is not a substitute for reading your plan document or contract or for advice from your own counsel. Figures shown are current as of the date on this page.
The plan reports its bond every year on the Form 5500. On Schedule H and Schedule I it is line 4e, in the compliance questions. On the Form 5500-SF it appears in the same compliance block. The question is simply whether the plan was covered by a fidelity bond, and if the answer is yes, the aggregate amount of coverage.
It is two boxes. It is also, for most plans, the most publicly visible compliance statement they make all year, because Form 5500 filings are published and searchable.
What the line asks#
The instructions to Schedule H put it plainly: plans that check "Yes" must enter the aggregate amount of fidelity bond coverage for all claims. The instructions cite ERISA section 412 and 29 CFR part 2580 directly, and they point to the definition of handling at 29 CFR 2580.412-6, the permissible bond forms at 29 CFR 2580.412-10, and the amount rules in subpart C.
Enter the bond’s limit, not the premium and not the plan’s assets. If more than one bond covers plan officials, the aggregate is what goes in the box.
Why a "no" is expensive#
Form 5500 filings are public. EBSA publishes the data, and it is searchable by anyone with a browser, including plaintiff’s firms that run systematic screens against it.
A "no" on line 4e is an unambiguous, self-reported, dated statement that the plan was not carrying a legally required bond. It is not a judgment call that can be argued about later. It is also trivially correlated with other fields in the same filing, so a plan that answers no is a plan that will be looked at more closely on everything else.
The practical reality is that this line is checked by the plan auditor, by the TPA preparing the filing, and by anyone doing due diligence on the plan. It is not a box that goes unread.
Know the amount you need? Apply for this bond, or read the full bond details.
The subtler failure: an amount that is too low#
Answering yes with an amount below 10 percent of the plan’s assets is arithmetic that anyone can do from the same filing, because the asset figure is right there on the balance sheet section.
It is the single easiest inconsistency to spot in a Form 5500, and it is common, because it is what happens when a plan is bonded once at inception and then grows. A plan reporting $2,400,000 in assets and a $10,000 bond has, in one filing, disclosed both the requirement and the failure to meet it.
If that describes a filing you have already made, the answer is not to leave it. Get bonded correctly now, and talk to the TPA or ERISA counsel about whether and how to address the prior years. Fixing it forward while ignoring the trail is the version that ages badly.
Where it sits on each form#
| Filing | Who files it | Where the bond is reported |
|---|---|---|
| Schedule H | Large plans, generally 100 or more participants | Part IV compliance questions, line 4e, with the amount |
| Schedule I | Small plans filing the full Form 5500 | Part II compliance questions, line 4e, with the amount |
| Form 5500-SF | Most eligible small plans | The compliance block, same question and amount |
| Form 5500-EZ | Owner-only plans | Not asked, because the plan is outside Title I and has no bonding requirement |
That last row is worth noticing. A plan filing the 5500-EZ is filing it precisely because it is not covered by Title I, which is the same reason it has no bond requirement. The two facts travel together. Why owner-only plans are outside Title I
A short pre-filing checklist#
- Pull the bond. Confirm it was in force for the entire plan year being reported.
- Confirm the plan name on the bond matches the plan name on the filing.
- Compare the bond amount to 10 percent of the highest funds handled during the year before the reported year.
- If more than one bond is in play, add the limits for the aggregate figure.
- Enter the limit. Keep the calculation with the plan records.
Five minutes, once a year, on the box that is most likely to be read by someone who is not on your side.
Common questions
What amount do I enter on Form 5500 line 4e?
The aggregate amount of fidelity bond coverage for all claims, meaning the bond limit. Not the premium, not the plan’s assets, and not 10 percent of anything. If several bonds cover plan officials, add the limits together.
What happens if I answer no on line 4e?
Nothing happens automatically, but you have made a public, dated, self-reported statement that a legally required bond was not in place. Form 5500 data is published and searchable. It is the kind of disclosure that draws attention to the rest of the filing, and it is very hard to characterize as anything other than what it says.
Is a fidelity bond reported on Form 5500-EZ?
No. The 5500-EZ is filed by owner-only plans, which are not covered by Title I of ERISA, which is the same reason they have no section 412 bonding requirement. If you are eligible to file the EZ, you are generally outside the bond requirement as well.
Our bond was in place for part of the year. What do we report?
Answer honestly about the coverage that existed and its amount, and expect a question about the gap. A partial year is a gap, and a gap in a required bond is a fiduciary issue rather than a reporting technicality. This is a point to raise with the TPA or ERISA counsel before the filing goes out rather than after.
Who actually checks line 4e?
The plan auditor, as a standard procedure on any audited plan. The TPA preparing the filing, usually. And anyone running screens on public Form 5500 data, which includes plaintiff-side firms. It is one of the more frequently read boxes on the form.
Get the bond filed today
Answer a few questions and see pricing for this bond. A standard ERISA fidelity bond is usually written without a personal credit check and is often issued quickly, because the bond protects the plan rather than guaranteeing your performance.
Apply for this bondFull bond details