New Form 5500 Requirements

Posted by BAS - 14 July, 2016

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Last week, the Department of Labor, Department of Treasury, and the Pension Benefit Guaranty Corporation issued 777 pages of proposed changes to Form 5500.  Form 5500 is an annual report required to be filed by retirement plans and certain health/welfare plans subject to ERISA.  The Form 5500 discloses information about the financial condition and operation of the plan.

The agencies found that the Form 5500 has not been updated to keep in step with changes in laws applying to employee benefit plans.  Therefore, a significant overhaul of the Form 5500 was required. Changes were also needed to keep pace with the EFAST filing system.

Notably, one change will require a return for small welfare plans- health plans with fewer than 100 participants.  These plans were previously exempted from filing requirements.

Changes are only in proposed form and will not be implemented until final.  Presumably, additional changes will be made before the revisions go into effect.  The proposed changes can be accessed here.  


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