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Advance copies of Anatomy 5500, acclimated to address on plan year 2019 benefits, reflect an access in best civilian penalties beneath the Agent Retirement Income Security Act (ERISA), amid added changes.

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The U.S. Department of Labor’s Agent Allowances Security Administration (EBSA), the IRS and the Alimony Account Guaranty Corp. (PBGC) appear beforehand copies of the 2019 Anatomy 5500 and accompanying instructions in November. For abate filers, beforehand copies of 2019 Anatomy 5500-SF (short form) and 2019 Instructions for Anatomy 5500-SF additionally were fabricated available, forth with added abstracts that accommodate schedules and attachments.

Form 5500 and appropriate schedules and accessories are acclimated to address the banking conditions, investments and operations of agent account plans, including:

Major Anatomy 5500 revisions that federal agencies had originally proposed for advertisement on plan year 2019 were never finalized, but the proposed check could be active and completed for approaching reporting, allowances admiral said.

Filing Requirements

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Advance copies of the 2019 Anatomy 5500 are for advisory purposes only. Official cyberbanking versions will be accessible on the federal government’s EFAST2 website in aboriginal 2020. Filers should adviser the website in January for the absolution of the official cyberbanking forms, the agencies advised.

Administrators or sponsors of agent account diplomacy accountable to ERISA charge book advice about anniversary account plan every year. A baby plan (generally one with beneath than 100 participants at the alpha of the plan year) may be acceptable to book Anatomy 5500-SF instead of Anatomy 5500. Moreover, some diplomacy with beneath than 100 participants are absolved from filing an anniversary acknowledgment or address beneath assertive conditions, as abundant in the Diplomacy Absolved from Filing area of the forms’ instructions.

Form 5500 anniversary acknowledgment or address filing is due on the aftermost day of the seventh ages afterwards the plan year ends, with an alternative two-and-a-half-month extension. For diplomacy that chase a agenda year, Anatomy 5500 for the above-mentioned year is due July 31 and on Oct. 15 with an extension.

[SHRM members-only HR Q&A: What is the ERISA Anatomy 5500?]

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Reporting Changes

The Changes to Note area of the 2019 instructions analysis the revisions to Anatomy 5500 and Anatomy 5500-SF, as able-bodied as updates to their schedules and instructions. Margaret Berger and Ellen Stone, principals in Mercer’s law and action group, accent two changes of absorption to retirement plan administrators:

The new catechism relates alone to contributions contributed at the end of the adroitness aeon (generally 1/2 months afterwards plan year-end), not to annual contributions paid backward but afore that deadline, Berger and Stone acicular out.

Other Anatomy 5500 changes for advertisement in 2020 accommodate the following:

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Big Changes on Hold

In 2016, the DOL, the IRS and PBGC proposed cogent revisions to Anatomy 5500. As SHRM Online reported, the revisions would abundantly aggrandize the blazon and bulk of advice to be collected, which would accommodate the following:

The greatest appulse would abatement on baby bloom and abundance plans. Many of these diplomacy are currently absolved from Anatomy 5500 advertisement requirements, but that absolution would no best apply.

However, efforts to agree the revisions, which were originally proposed to booty aftereffect for plan year 2019 reporting, accept been put on hold, said Lisa Allen, carnality admiral of authoritative diplomacy at Relph Account Admiral in Fairport, N.Y. She additionally afresh served on the IRS Advisory Council.

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The DOL and IRS “are so far abaft due to implementing the Tax Cuts and Jobs Act that I don’t see them acrimonious this aback up” anytime soon, Allen said.

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