The IRS, the Department of Labor (DOL) and the Pension Benefit Guaranty Corporation (PGBC) published proposed updates to the Form 5500 annual return in the Federal Register on July 21, 2016, that could have a significant effect on plan reporting. Plans subject to the Employee Retirement Income Security Act of 1974 (ERISA) must file annual returns, the Form 5500 or for small filers, the Form 5500-SF along with required attachments and schedules. The IRS, the DOL and the PGBC use the information reported to enforce compliance with ERISA, but the data also provide plan participants insight into the way their retirement plan operates.

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A publication of the Professional Standards Group
September 2016
Joint Effort Could Signal Major Form 5500 Changes
The IRS, the Department of Labor (DOL) and the
Pension Benefit Guaranty Corporation (PGBC)
published proposed updates to the Form 5500 annual
return in the Federal Register on July 21, 2016, that
could have a significant effect on plan reporting.
Plans subject to the Employee Retirement Income
Security Act of 1974 (ERISA) must file annual returns,
the Form 5500 or for small filers, the Form 5500-SF
along with required attachments and schedules. The
IRS, the DOL and the PGBC use the information
reported to enforce compliance with ERISA, but the
data also provide plan participants insight into the
way their retirement plan operates.
Proposed updates to the Form 5500 (Report of
Employee Benefit Plan) and the Form 5500-SF
(Report of Small Employee Benefit Plan) came in
two parts, annual information and return reports
and annual reporting and disclosure. Both sets of
changes would require additional information from
plan filers that would assist the agencies with their
compliance monitoring and provide data the public
and beneficiaries could use to understand plans and
their investments. Taken together, the changes fulfill
five goals:
• Modernize financial reporting
• Provide greater information regarding group
health plans
• Enhance data mineability
• Improve service provider fee information
• Enhance compliance with ERISA and the code.
The proposed changes to the Form 5500 would
significantly increase reporting obligations for health
and welfare plans.
All updates to the Form 5500 are also coordinated
with updates to the ERISA Filing Acceptance System
II (EFAST2), the electronic processing system for the
Form 5500 and Form 5500-SF.
Most of the changes take effect for the Plan Year 2019
Form 5500. Comments on the changes are due to the
DOL before October 4, 2016.
Stay tuned for more information about how the various
proposed changes could affect your reporting. For
specific comments, questions or concerns about
the changes, please contact Hal Hunt of MHM’s
Professional Standards Group. Hal can be reached at
hhunt@cbiz.com or 816.945.5610.