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2015 Form 5500, Instructions Available

The Department of Labor (DOL), IRS and Pension Benefit Guaranty Corporation (PBGC) on Dec. 3 released advance copies of the Form 5500 Series to be used for 2015 reporting.

Filings on 2015 forms can be submitted to EFAST2, the electronic system by which the Form 5500 is submitted, through approved software beginning 4:00 a.m. EST on Jan. 1, 2016. 

The 2015 Form 5500 is available here; the instructions are available here.

Following are the changes made to the Form 5500 for 2015 reporting.

IRS Electronic Filing Requirements

On Sept. 29, 2014, the Treasury Department issued final regulations providing that certain
filers must electronically file the Form 5500 Series, including actuarial schedules. Under these regulations the Form 5500 series return/report is to be filed electronically if a filer is required to file at least 250 returns of all types during the calendar year that includes the first day of the applicable plan year.

Because the IRS may now require certain filers to electronically file the Form 5500 Series, the IRS is adding questions to the Form 5500 and its schedules relating solely to IRS compliance issues. However, these new IRS compliance questions are optional for the 2015 plan year.

IRS Compliance Questions

These questions are optional for the 2015 plan year:

  • New lines 4o, 4p 6c and 6d were added to Schedules H and I. The IRS is encouraging filers to answer these questions relating to unrelated business taxable income, in-service distributions and trust information.

  • New Part VII (IRS Compliance Questions) was added to Schedule R for purposes of satisfying the reporting requirements of section 6058 of the Code. The IRS is encouraging filers to answer these questions even though they are optional for the 2015 plan year.

Schedule MB

The Schedule MB is modified in the following manner:

  • The instructions are modified to add RP-2000 and RP-2000 (with Blue Collar Adjustment) to the list of mortality tables for non-disabled lives that plans may report in line 6c.

  • The schedule and instructions are also modified to add a new question in line 8b that would require large multiemployer plans (those with 500 or more total participants as of the valuation date) to provide in an attachment a projection of expected benefit payments to be paid for the entire plan (not including expected expenses) for each of the next 10 plan years starting with the plan year to which the filing relates. The Schedule MB is modified to require all multiemployer plans to report the funded percentage for monitoring the plan’s status in line 4.

  • As a result of the enactment of the Multiemployer Pension Reform Act of 2014, the schedule and its instructions are further modified to extend the reporting requirements in line 4 for multiemployer plans in critical status to plans in critical and declining status and require that additional information to be reported by plans that have been partitioned or have had benefits suspended.

Schedule SB

The instructions are modified to simplify the alternative age/service scatters that cash balance plans with 1,000 or more active participants have an option to report on an attachment to line 26.

Form 5500 Final Return/Report for Plans Trusteed by the PBGC

The instructions for “Final Return/Report” are modified to add a statement that a filer for a terminated defined benefit plan for which the PBGC has been appointed trustee may contact the DOL at [email protected] for further information.