DOL Publishes Advance Copies of 2017 Forms 5500 and 5500-SF

On Nov. 20, 2017, the DOL published advance information copies of the 2017 Form 5500 return/report, which includes Form 5500-SF and corresponding instructions. These advance copies are only for informational purposes and may not be used for 2017 Form 5500 or 5500-SF filings, but employers should familiarize themselves with the changes in preparation for 2017 plan year filings. Important modifications to the Form 5500 and Form 5500-SF instructions and schedules are summarized below.

First, for the 2017 plan year forms, the IRS has removed the “IRS-only questions” that filers weren’t required to complete in 2016. As background, in 2016, the IRS instructed filers to omit the “Preparer’s Information” on Form 5500, questions on lines 4o, 6a through 6d of Schedules H and I, and the “Part VII – IRS compliance Questions” of Schedule R. Similarly, filers using Form 5500-SF should skip the “Preparer’s Information” section, “Part VIII – Trust Information” and “Part IX – IRS Compliance Questions.” This year’s forms have removed those questions all together.

Second, the instructions have been updated to reflect the fact that authorized service providers can now sign the Form 5500 on the plan sponsor line.

Third, the instructions have been updated to reflect an increase in the administrative civil penalties assessable under ERISA, which have increased to a maximum of $2,097 per day for a plan administrator’s failure or refusal to file a complete and/or accurate Form 5500 report.

Fourth, line four has been changed to provide a field for filers to indicate that the name of the plan has changed.

While many employers outsource the preparation and filing of these forms, employers should also familiarize themselves with the new requirements and work closely with outside vendors to collect the applicable information.

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Form 5500 Series Forms and Instructions »