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The Department of Labor (DOL) finalized its Form 5500 regulations in late July, pushing back the deadline for electronic-only filings another year and providing a preview of things to come.
The major difference between the Proposed Regulations issued last year and the Final Regulations is that the electronic-only filing requirement has been delayed for an additional year. It is now effective for plan years that begin on or after January 1, 2008. This regulation impacts all plan sponsors of ERISA welfare and pension benefit plans, including group health plans. Recall, that while Technical Release 92-01 exempted Cafeteria Plans from 5500 filing, the requirement still exists for the component plans offered through a Cafeteria Plan (e.g., group health plans).
In addition, IRS is tweaking the form itself, removing some schedules (e.g., Schedule E—ESOP Annual Information and Schedule SSA—Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits). IRS will replace the existing system called EFAST (ERISA Filing Acceptance System) with a new processing system. Filers will have two options: Enter the data directly through the Internet or transmit the data through an XML data feed. Additional details will be forthcoming.
DOL rejected a request that it forego issuing civil penalties for a transition period as plans adjust to the new filing requirements.
On the same day, DOL issued Proposed Regulations related Form 5500. The major highlight is a new Short Form 5500-SF, which would be available for small plans with fewer than 100 participants. Recall that previously DOL issued a 5500 filing exemption to certain unfunded and insured welfare plans with fewer than 100 participants at the start of the plan year. That exemption remains unchanged.
While Infinisource does not currently provide services related to the completion of Form 5500, we do provide regular reports on activity related to those services and can provide a summary of administrative charges that aid in the completion of Form 5500. You may access the DOL Form 5500 regulations at:
www.dol.gov/ebsa/compliance_assistance.html#section5.
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