Form 5500 Deadline Looms

Defined benefit plans, defined contribution plans and 403(b) annuity arrangements with calendar year plans, take note: July 31 is right around the corner. That’s the day by which most plans must file the dreaded and onerous Form 5500. The clock is ticking on filing the form that reports on 2014.

The form must be filed by the end of the seventh month after the end of a plan year. Plans that use the federal fiscal year — Oct. 1-Sept. 30 — have to file by April 30. But since most plans set their plan years to the calendar year, most plans have to file by July 31. So calendar-year plans must file the 2014 Form 5500 by July 31, 2015.

Of special note for retirement plans is a change made to Part I of the form. The check box for “Multiple-Employer Plans” in Part I of the Form 5500 has been changed to indicate that multiple-employer pension plans and multiple-employer welfare plans required to file a Form 5500 must include an attachment that:

• identifies each participating employer in the plan during the plan year by name and employer identification number (EIN); and

• includes a good faith estimate of each employer’s percentage of the total contributions (including employer and participant contributions) made by all participating employers during the year.

In addition, like other employee plans, retirement plans should recall two other changes for 2014 reporting:

• Signature and Date. The instructions for “Signature and Date” have been updated to caution filers to check the filing status and to advise that if the filing status is “Processing Stopped” or “Unprocessable,” it is possible that the submission was not sent with a valid electronic signature as required, and — depending on the error — may be considered not to have been filed. By looking closer at the filing status, you can see specific error messages applicable to the transmitted filing and determine whether it was sent with a valid electronic signature and what other errors may need to be corrected.

• Active Participants Information. A new question, “Total number of active participants at the beginning of the plan year,” has been added to Line 6a(1).