<p>It looks like you have a 409a plan. A person on the FAFSA helpline said it does not need to be reported as an asset because it is not one of the specific assets listed in the notes for question 89. It is also not one of the investments listed in the notes as those that don’t count, such as 401K’s and IRA’s. I have a call into my employer’s helpline as well, but would be interested to see if anyone has ever gotten a specific ruling on 409a plans.</p>