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Copies of the
2014 Form 5500 annual return/report and related instructions were recently released by the U.S. Department of Labor (DOL), the Internal Revenue Service (IRS) and the Pension Benefit Guaranty Corp. (PBGC). These copies are for informational purposes only and cannot be used to file an annual return/report.
All Form 5500 annual returns/reports of employee benefit plans, and all Form 5500-SF (short form) annual returns/reports of small employee benefit plans and any required schedules and attachments, must be completed and filed electronically using
EFAST2-approved third-party software or using
IFILE. For more information on completing and filing forms electronically through EFAST2, see the
EFAST2 FAQs and
Modifications to Form 5500 and Form 5500-SF, and their schedules and instructions for plan year 2014, are described under “Changes to Note” in the 2014 instructions. Examples of these changes include:
• DOL Form M-1 compliance information. The Multiple Employer Welfare Arrangements (MEWA) Form M-1 compliance information that was filed as an attachment for 2013 now appears as three new questions on Form 5500.
• Signature and date. The Form 5500 and Form 5500-SF instructions for “Signature and Date” have been updated to caution filers to check the filing status. If the filing status is "Processing Stopped" or “Unprocessable,” the submission may not have had a valid electronic signature and, depending on the error, may be considered not to have been filed.
• Active participant information. Filers are now required to provide the total number of active participants at the beginning of the plan year and at the end of the plan year on both forms.
• Terminated participant vesting information. Form 5500-SF filers now must provide the number of participants that terminated employment during the plan year with accrued benefits that were not fully vested.
• Multiple-employer plan information. In accordance with the
Cooperative and Small Employer Charity Pension Flexibility Act, Form 5500 and Form 5500-SF now require multiple-employer pension plans and multiple-employer welfare plans to include an attachment that generally identifies each participating employer, and includes a good-faith estimate of each employer's percentage of the total contributions during the year.
• Schedule H. The instructions for line 1c(13) have been enhanced to set out what is an investment company registered under the Investment Company Act of 1940.
• Schedule MB. New line 4f requires plans in critical status to indicate the plan year in which a plan is projected to emerge from critical status or, if the rehabilitation plan is based on forestalling possible insolvency, the plan year in which insolvency is expected.
• Schedule SB. Line 3 has been modified so that the funding target is reported separately for each type of participant (active, retired or terminated vested). Line 11b has been split into two parts: the calculation based on the prior year’s effective interest rate, and the calculation based on the prior year’s actual return. Line 15 instructions have been expanded to address situations in which the adjusted funding target attainment percentage (AFTAP) was not certified for the plan year. Line 27 and related instructions have been modified to reflect funding changes under the Cooperative and Small Employer Charity Pension Flexibility (CSEC) Act for defined benefit pension plans impacted by the act.
Filers should monitor
the EFAST website for the availability of the official electronic versions of Form 5500 and Form 5500-SF, for filing using EFAST-approved software or directly through the EFAST website. Assistance with the EFAST2 system is
available online or by calling 1-866-463-3278.
2014 Form M-1 for Multiple Employer Welfare Arrangements
The Department of Labor also announced the availability of the 2014 Form M-1 annual report for multiple employer welfare arrangements. The 2014 form and instructions were updated with minor clarifications, and there are no substantive changes from the previous year’s form. The online filing system is available at
www.askebsa.dol.gov/mewa. Assistance with online filing is available by calling 202-693-8600. Information about the Form M-1 and how to fill it out is available on the site or by calling 202-693-8360.
Related External Article:
Advance Copies of 2014 Form 5500s Reminder to Avoid Penalties By Confirming Compliance, HR & Benefits Law Update (Solutions Law Press), December 2014
Related SHRM Articles:
What is Form 5500, and where are instructions for completing it?, SHRM HR Q&As, March 2013
DOL Issues Final Rule for Multiple-Employer Health Plans,
SHRM Online Benefits, March 2013
DOL Launches Mandatory Form 5500 Online Filing System,
SHRM Online Benefits, January 2010
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