CUSTODIAN DESIGNATION CONTROL AND REPORTING CHECKLIST

Reporting Year / Cycle:
Reviewer Name / Department:
Date of System Review:

INTAKE CONTROLS (JAN 1 - APR 15)
[ ] Online banking portal prompts users for tax year designation.
[ ] Teller/branch systems require tax year selection for HSA deposits.
[ ] ACH/batch processing holds undefined deposits for exception review.
[ ] Default allocation rules are documented for non-responsive depositors.

EMPLOYER CONTRIBUTION PROCESSING
[ ] Dedicated channel established for employer allocation notices.
[ ] Employer prior-year allocations are verified against batch totals.
[ ] System successfully splits mixed-batch files into current and prior year buckets.

FORM 5498-SA DATA EXTRACTION
[ ] Box 2 logic sums ALL deposits received Jan 1 - Dec 31 (inclusive of prior-year designations).
[ ] Box 3 logic looks ahead to Jan 1 - Apr 15 of the subsequent year.
[ ] Box 3 extract strictly filters for prior-year participant/employer designations only.
[ ] Test extraction confirms no prior-year designations were subtracted from Box 2.

FURNISHING AND COMPLIANCE
[ ] Statements prepared for the adjusted May deadline: June 1, 2027 for 2026 reporting.
[ ] Customer support scripts updated to explain Box 2 / Box 3 overlap.
[ ] Correction workflow established for disputed designations.
[ ] All original deposit instructions and notices securely archived.