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Agencies Release 2019 Form 5500, Schedules, and Instructions



2019 Form 5500, Schedules, and Instructions

The DOL, IRS, and PBGC have released advance information copies of the 2019 Form 5500 series, including Schedules and Instructions. (As a reminder, these copies cannot be used for filing; with very limited exceptions, Form 5500 must be filed electronically.) Here are highlights of changes relating to welfare and 401(k) plan filings:

  • Annually Adjusted Penalties. The instructions have been updated throughout to reflect the current maximum penalty for Form 5500 filing failures ($2,194 per day). Filers are also reminded to check for increases, as required annual adjustments take place after these forms and schedules have been published (see our Checkpoint article).
  • Business Code for Sponsors of Multiemployer Plans. The instructions for Line 2d clarify how to report a plan sponsor’s business code for multiemployer plans.
  • Accountant’s Opinion. The instructions for Schedule H, Part III (Accountant’s Opinion) have been updated to correspond with changes to generally accepted auditing standards impacting benefit plans. (Schedule H, including the accountant’s opinion, is generally required for large 401(k) plans and large funded welfare plans.)

EBIA Comment: Although the changes to Form 5500 for 2019 are not extensive, those responsible for filing should review the updated Instructions carefully to ensure complete and accurate filing of Form 5500 and any necessary Schedules. For more information, see EBIA’s ERISA Compliance manual at Section XXII (“Annual Form 5500 Reporting to the DOL”) and EBIA’s 401(k) Plans manual at Section XXXI (“Plan Administration: Annual Form 5500 Reports and SARs”). See also EBIA’s Cafeteria Plans manual at Section XXXIV (“Form 5500 and Other Reporting Requirements”) and EBIA’s Self-Insured Health Plans manual at Section XXIX.B (“Annual Form 5500 Reporting”).

Contributing Editors: EBIA Staff.

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