Form 5500 isn’t just transforming disclosures as our friend and fellow blogger, Bob Toth, explained in his post 2009 Form 5500 Schedules A and C Will Create New Fiduciary Burdens For Plan Sponsors.
The reporting road will be also be different, and there will be red flags along the way.
Beginning with the 2009 plan year, the Department of Labor (DOL) will require retirement and welfare plans to file their Form 5500 electronically. It’s called EFAST 2, and it’s effective for plan years beginning on or after January 1, 2009. Electronic filing will be available starting January 1, 2010.
All plans, including retirement, welfare and 403(b) plans, will need to file their 5500s electronically except for “owner-only plans”. These are plans covering the sole owner (and his/her spouse) or partners in a partnership (and their spouses) and no employees. Owner only plans can continue to file a paper copy of the 5500-EZ with the IRS. However, owner-only plans, which do not hold employer stock, may elect to file a Form 5500-SF (short form) electronically with the DOL.
While the transformation from paper filing to electronic filing will require significant procedures changes for those of us involved in plan administration, the ultimate challenge may be dealing with those clients who are not exactly high up on the technology curve. But then, that’s what client service is all about.