July 14, 2016

Complete Restructuring of Form 5500 Proposed for 2019

On July 11, 2016, the Departments of Labor and the Treasury and the Pension Benefit Guaranty Corporation (Agencies) issued the Form 5500 Improvement and Modernization Proposal, a voluminous package of guidance and related materials (almost 1000 pages), in which they have proposed a complete restructuring of the Form 5500 annual return/report, including all Schedules. The Agencies view the changes as necessary to modernize and improve the Form, noting that the last comprehensive update focused on revising the forms in anticipation of mandatory electronic filing beginning with the 2009 plan year.

The revised forms are not expected to be used until the 2019 plan year at the earliest because changes will need to be coordinated with changes in the E-FAST filing system, which require considerable lead time. 

The Agencies state that the revisions are intended to:

  • Modernize the financial statements and investment information filed about employee benefit plans;
  • Update the reporting requirements for service provider fee and expense information;
  • Enhance accessibility and usability of data filed on the forms;
  • Require reporting by all group health plans covered by Title I of ERISA; and
  • Improve compliance under the Employee Retirement Income Security Act and the Internal Revenue Code through new questions regarding plan operations, service provider relationships and financial management of the plan.

The guidance is expected to be published in the Federal Register on July 21, 2016. Comments are due by October 4, 2016.

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