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.
