The American Retirement Association on May 31 submitted a letter to the IRS on the proposed compliance questions for the Form 5500 series. The IRS had requested comments on the questions, which currently are under consideration for addition to the 2016 Forms 5500-EZ and 5500-SF, and to Form 5500 Schedules H, I and R, along with the proposed Form 5500-SUP.
The ARA has previously expressed its concerns to the IRS, Treasury and the Office of Management and Budget (OMB) about the compliance questions on the 2015 Form 5500 series, the letter notes, including the new proposed Form 5500-SUP. ASPPA had submitted comments in February 2015 to the IRS regarding some of its concerns about the additional data collection required by the Form 5500-SUP; the ARA also sent a letter to OMB on June 8, 2015 about the burden to filers and their service providers in providing this data relative to the 2015 reporting year.
“While we appreciate the extensive revisions that have been made to the questions, we remain concerned regarding the timing of implementation,” says the ARA in the May 31 letter. The ARA made specific recommendations.
The effective date for mandatory collection of information solicited by the new compliance questions should be delayed to coincide with the proposed Form 5500 revisions expected from the Department of Labor which are currently being reviewed by OMB before being published and public comment solicited, the letter says. “By the time final forms and instructions are issued for this iteration of IRS compliance questions, it will be extremely difficult to implement for the 2016 plan year,” it argues.
The request for the employer identification number (EIN) of the plan’s trust should remain an optional question at least for the next two plan years, the ARA also says. This, it argues, would “provide time for plan sponsors to determine whether a trust EIN has been deactivated by the IRS or to apply for an EIN.”
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