Agencies Collaborate to Propose Revisions to Forms for Employee Benefit Plans

The Internal Revenue Service (IRS), Department of Labor (DOL), and Pension Benefit Guaranty Corporation (PBGC) have jointly issued proposed revisions to the Form 5500 Series of annual returns, reports and schedules filed by certain employee benefit plans. See the IRS website for details/deadlines for current forms.

The proposed changes reflect joint efforts by these agencies to improve employee benefit plan reporting for filers, the public and the agencies. The new revisions, contained in an incredibly lengthy document (nearly 800 pages!), address the following objectives:

  • Modernizing financial information filed regarding plans;
  • Updating fee and expense information on plan service providers with a focus of harmonizing annual reporting requirements with the DOL’s final disclosure; requirements that enhancing mine-ability of data filed on annual returns/reports;
  • Requiring reporting by all group health plans covered by Title 1 of the Employment Retirement Income Security Act (ERISA); and
  • Improving compliance with ERISA and the Internal Revenue Code (Code).

Among a number of other changes, the proposed revisions reintroduce Schedule E (ESOP Annual Information) and add various questions to Form 5500 related to common compliance problems.

The proposed revisions generally would apply for plan years beginning on or after January 1, 2019 (i.e., the 2019 Form 5500). If adopted, the  new rules  would  affect  employee  pension  and welfare  benefit  plans,  plan  sponsors, administrators  and service  providers  to plans  subject  to annual  reporting  requirements  under ERISA  and the  Code.

An open comment period has been made available for those affected by the rules and written comments regarding the Notice must be received by the DOL on or before October 4, 2016.

Questions and/or comments regarding the new changes may be directed to Bob Grossman or Don Johnston.

Picture of Bob Grossman

Bob Grossman

Bob, one of the firm’s founding partners, has over 40 years of experience in public accounting. He specializes in tax and valuation issues that affect businesses as well as their stakeholders and owners. Bob has extensive experience working with the Internal Revenue Services and also serves as an expert witness in litigation matters.
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