2017 Form 5500 annual return/report series issued

The Employee Benefits Security Administration (EBSA), the IRS, and the Pension Benefit Guaranty Corporation (PBGC) have issued advance informational copies of the 2017 Form 5500 annual return/report, related instructions and schedules, and 2017 Form 5500-SF and instructions. The advance copies cannot be used to file a 2017 form. Plans should file Form 5500 or Form 5500-SF electronically using the EFAST 2 system.

IRS compliance questions

IRS-only questions that filers were not required to complete on the 2016 Form 5500, Form 5500-SF, and Schedules H, I, and R have been removed from the 2017 forms and schedules. These removed questions include preparer information, trust information, Schedules H and I Lines 4o, and Schedule R, Part VII, on IRS Compliance questions.

Authorized service provider signatures

The instructions for authorized service provider signatures have been updated to reflect the ability for service providers to sign electronic filings on the plan sponsor and Direct Filing Entity (DFE) lines in addition to signing on behalf of plan administrators.

Administrative penalties

The instructions for 2017 Forms 5500 and 5500-SF have been updated to reflect an increase in the maximum civil penalty amount assessable under ERISA Sec. 502(c)(2), as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (P.L. 114-74). The maximum penalty was increased to $2,097 a day for a plan administrator who fails or refuses to file a complete or accurate Form 5500 report. The increased penalty under Sec. 502(c)(2) is applicable for civil penalties assessed after January 13, 2017, whose associated violation(s) occurred after November 2, 2015 – the date of enactment of the Act.
The instructions note that filers should check for any further inflation adjustments because the penalty amounts are adjusted after the Forms 5500 and instructions are issued.

Plan name change

Lines 4 of the Form 5500 and Form 5500-SF have been changed to provide a field for filers to indicate that the name of the plan has changed. The instructions for the Lines 4 have been updated to reflect the change. The instructions for Line 1a have also been updated to advise filers that if the plan changed its name from the prior year filing(s), complete Line 4 by providing the old plan name.

PBGC question for Form 5500-SF

Line 6c in Form 5500-SF has been modified to add a new question for defined benefit plans that answer “Yes” to the existing question about whether the plan is covered under the PBGC insurance program. The new question asks these plans to enter the confirmation number generated in the “My Plan Administration Account system” for the PBGC premium filing for the plan year to which the Form 5500-SF applies. For example, the confirmation number for the 2017 premium filing is reported on the 2017 Form 5500-SF.

Schedule MB

The instructions for Line 6c have been updated to mortality codes for several variants of the RP-2014 mortality table and to add a description of the mortality projection technique and scale to the attached statement of actuarial assumptions, “Schedule MB, line 6 – Statement of Actuarial Assumptions/Methods”.
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