Organizing the Census Information
January 23, 2007

One of the most important items that you will need to organize and provide to the internal or external recordkeeper is the census information. Unless this is the first year of your ESOP, you will most likely have an established file format to follow when organizing the census information. If the information is requested in a format that would cause you a lot of additional time and effort, you should discuss this with your recordkeeper. Here is a general list of the items you will need to include in this file:

• Name (ideally split by first, middle, and last name)
• Social Security (or other identification) number
• Dates of birth, original hire, current hire, and current termination
• Gross wages
• Either eligible wages per the plan document or excludable wages (e.g. bonuses, commissions) so the eligible wages can be calculated
• Other qualified plan contributions (split by item, e.g. 401(k) deferrals, 125 deferrals, employer matching contributions, matching forfeitures, other plan contributions, other plan forfeitures)
• Hours worked during plan year

Here are some things to consider when providing the above-mentioned information:

• If the original date of hire and the current date of hire are not the same, then enough information should be provided so the relevant employment history can be determined. This certainly includes all dates of hire and termination in the current year.
• All employees should be provided. You should be able to reconcile the wages to the IRS Form W-3 and IRS Forms 941. You should be able to reconcile all other totals to source documents as well.
• If your plan only considers compensation while a participant and you have quarterly or semi-annual participation dates, it would be helpful to split the wages by the applicable period (if the information is easily attainable).
• If your plan considers the hours in the first 12 months of employment (and in some cases each additional 12-month period), you should also provide the hours during that 12-month period (if the information is easily attainable).

In addition, here are some additional items that you should provide, if applicable and possible:

• Division information
• Employee status (e.g. actively employed at the end of the plan year, not actively employed at the end of the plan year, not actively employed at the end of the plan year as a result of death)
• Address (street address, city, state, and zip)
• Gender
• Beneficiary(s)
• Any other relevant information

As mentioned above, if providing any of this information is challenging, you should discuss this with your recordkeeper or consultant to figure out the most efficient and effective way to obtain and provide this information. They may have some suggestions that will simplify the process or determine that the information is not needed for the administration of your plan.

The earlier this information is organized, the earlier the eligibility can be finalized, the maximum contribution can be determined, and the allocations can be processed. Your goal should be to have this information organized between 15 to 30 days after the end of the plan year.