December 10, 2015

Advance Copies of 2015 Form 5500 Released: Are You Prepared for the New Requirements?

The Department of Labor, the Internal Revenue Service (IRS) and the Pension Benefit Guaranty Corporation, the agencies responsible for implementing the Employee Retirement Income Security Act (ERISA), have released advance copies of the 2015 Form 5500 annual report and related schedules, which generally will be due for calendar-year plans no later than October 15, 2016.

The major change in the 2015 Form 5500 is to the Schedule R, where the IRS has added a new Part VII with a series of compliance questions. The questions are applicable to all qualified plans, including 401(k) plans, and cover issues related to nondiscrimination testing and compliance with plan amendment requirements. Because of the late issuance of the 2015 forms, completing Part VII is optional (but encouraged) for the 2015 Form. Completion will be required starting with the 2016 Form 5500.

In addition, the agencies made number of changes to the Schedule MB, the schedule for actuarial information. Those changes include requiring large multiemployer plans (i.e., those with 500 or more participants) to attach a projection of expected benefit payments for each of the next ten plan years starting with the plan year to which the filing relates, and also requiring the funded percentage of all plans (not just plans that are in endangered or critical status) to be reported.

The Department of Labor, the Internal Revenue Service (IRS) and the Pension Benefit Guaranty Corporation, the agencies responsible for implementing the Employee Retirement Income Security Act (ERISA), have released advance copies of the 2015 Form 5500 annual report and related schedules, which generally will be due for calendar-year plans no later than October 15, 2016.

The major change in the 2015 Form 5500 is to the Schedule R, where the IRS has added a new Part VII with a series of compliance questions. The questions are applicable to all qualified plans, including 401(k) plans, and cover issues related to nondiscrimination testing and compliance with plan amendment requirements. Because of the late issuance of the 2015 forms, completing Part VII is optional (but encouraged) for the 2015 Form. Completion will be required starting with the 2016 Form 5500.

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Serena Simons

Serena Simons

SVP, National Retirement Compliance Practice Leader