Look but Don’t Touch: Take a Sneak Peek at the 2011 Form 5500

Advance copies of the 2011 Form 5500 annual return/report and related instructions are now available for  your viewing pleasure — the issuing federal agencies note the forms are for “informational purposes” only, so don’t use them to get a head start on your filing responsibilities.

The advance copies were jointly issued by the U.S. Department of Labor’s (DOL’s) Employee Benefits Security Administration, the IRS and the Pension Benefit Guaranty Corp. Each year, pension and welfare benefit plans must electronically file an annual return/report regarding their financial conditions, investments and operations — filing the Form 5500 or Form 5500-SF (and any required schedules and attachments) generally satisfies that requirement.

Here are some changes that plan sponsors will see in the 2011 forms, as noted in a DOL press release:

• The actuarial schedules (Schedule MB and Schedule SB) have been updated to reflect provisions of the Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010 (“PRA 2010”).
• The instructions are updated to include the information in the EFAST2 Frequently Asked Questions explaining when a service provider who manages the filing process for the plan can get EFAST2 signing credentials and submit the electronic Form 5500 for the plan.
• The Schedule C instructions are updated to advise that for a multiemployer or multiple-employer plan, where the “plan sponsor” is the joint board of trustees for the plan, payments by contributing employers, directly or through an employer association, or by participating employee organizations, should be treated the same as payments by a plan sponsor.
• The Schedule I and Form 5500-SF instructions are updated to advise that for plans with fewer than 100 participants at the beginning of the plan year, any amount deposited with or repaid to such plan not later than the 7th business day following the day on which such amount is received by the employer or on which such amount would otherwise have been payable to the participant in cash, shall be deemed to be contributed or repaid to such plan on the earliest date on which such contributions or participant loan repayments can reasonably be segregated from the employer’s general assets.

The “information copies” of the forms, schedules and instructions are available at http://www.efast.dol.gov and http://www.dol.gov/ebsa/5500main.html. DOL states that filers should monitor the EFAST website to see when the official electronic versions become available.

See this article for information about the required use of electronic signatures when filing the Form 5500.

In addition, tips on filing the Form 5500 can be found in Employer’s Handbook: Complying with IRS Employee Benefits Rules.