In a public comment letter, ASPPA has asked the IRS to permit filers to complete the 2015 Form 5500-SUP (and/or the equivalent items appearing on the 2015 Form 5500 series, including the paid preparer disclosure) on a voluntary (i.e., optional) basis. ASPPA has previously expressed its concerns to both the IRS/Treasury and the Office of Management and Budget (OMB) about the 2015 Form 5500 series, including the new Form 5500-SUP, and continues to strongly reiterate them.
ASPPA appreciates the willingness of the IRS to provide FAQs or revise future forms and instructions to clarify the responses required for the SUP-data. But ASPPA also notes that no official guidance is available that would enable service providers to take decisive action on developing procedures for the collection of the SUP-data and that the draft forms and instructions are not yet final and continue to raise numerous questions.
ASPPA maintains that service providers and software vendors need adequate time to develop and implement sufficient mechanisms to respond to this initiative in order for the systems to be developed and data collection to be accurate and meaningful to the IRS.
Further, ASPPA urges the IRS to consider the processes described in OMB’s Aug. 9, 2012 memo regarding Testing and Simplifying Federal Forms. ASPPA strongly recommends that the IRS allow additional time to make the SUP-data collection less complex, burdensome and confusing to ensure that the agency collects the best data possible.
Key points ASPPA raised to support its position include:
ASPPA adds that many service providers are now devoting much of their technical staff and resources to the restatement of defined contribution plan documents in order to meet the April 30, 2016 deadline the IRS imposed for that. This work, ASPPA notes, severely limits the resources available and will further affect the industry’s ability to effectively respond to the SUP-data collection requirements.
Because of the considerable time and expense involved in meeting the requirements of the SUP-data collection the IRS proposed, ASPPA has asked that filers be permitted to provide such information for the 2015 reporting year on a completely voluntary (optional) basis.
ASPPA appreciates the willingness of the IRS to provide FAQs or revise future forms and instructions to clarify the responses required for the SUP-data. But ASPPA also notes that no official guidance is available that would enable service providers to take decisive action on developing procedures for the collection of the SUP-data and that the draft forms and instructions are not yet final and continue to raise numerous questions.
ASPPA maintains that service providers and software vendors need adequate time to develop and implement sufficient mechanisms to respond to this initiative in order for the systems to be developed and data collection to be accurate and meaningful to the IRS.
Further, ASPPA urges the IRS to consider the processes described in OMB’s Aug. 9, 2012 memo regarding Testing and Simplifying Federal Forms. ASPPA strongly recommends that the IRS allow additional time to make the SUP-data collection less complex, burdensome and confusing to ensure that the agency collects the best data possible.
Key points ASPPA raised to support its position include:
- While there may be a limited number of filers that will have little difficulty capturing accurate data on the 2015 Form 5500 series, the process is completely dependent on the nature of the service model employed to provide compliance, plan document and Form 5500 preparation services to the plan.
- When distinct computerized systems are utilized and multiple service providers are engaged by the plan, such businesses must arrange to reprogram systems and to coordinate manual collection of the required information — and these businesses will wait until final forms and instructions are issued before updating their systems.
- It generally takes at least 12 months for the necessary capital investments to be approved and technology, communication and procedural changes to be developed, tested and implemented. Further complicating the process, most companies have already set their budgets for 2016.
ASPPA adds that many service providers are now devoting much of their technical staff and resources to the restatement of defined contribution plan documents in order to meet the April 30, 2016 deadline the IRS imposed for that. This work, ASPPA notes, severely limits the resources available and will further affect the industry’s ability to effectively respond to the SUP-data collection requirements.
Because of the considerable time and expense involved in meeting the requirements of the SUP-data collection the IRS proposed, ASPPA has asked that filers be permitted to provide such information for the 2015 reporting year on a completely voluntary (optional) basis.
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