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Form 5500 Filing Date Approaching

July is next month. Obvious, but important for DB plans, DC plans and 403(b) annuity arrangements with calendar year plan years to keep that in mind, since that means the July 31 Form 5500 filing deadline for 2015 is not far off.

Filers should remember that the following changes were made for 2015:

IRS Electronic Filing Requirements. On Sept. 29, 2014, the Treasury Department issued final regulations under Code Sections 6058 and 6059 providing that certain filers must electronically file the Form 5500 series. Electronic filing of the Form 5500 is required for filers that have to file at least 250 returns of all types during the calendar year that includes the first day of the applicable plan year.

Since the IRS may now require certain filers to electronically file the Form 5500 series returns/reports, the IRS has added questions to the Form 5500 and its Schedules relating solely to IRS compliance issues. It is important to note, however, that these new IRS compliance questions are optional for the 2015 plan year.


Schedule MB.
The instructions for the schedule are modified in the following ways:

  • adding 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;

  • adding a new question in line 8b that would require large multiemployer plans (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; and

  • requiring all multiemployer plans to report the funded percentage for monitoring the plan’s status in line 4.

Schedule SB. The instructions for this schedule 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 PBGC. The instructions for “Final Return/Report” are modified to add a statement that a filer for a terminated DB plan for which PBGC has been appointed trustee may contact the Department of Labor at [email protected] for further information.