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2015 Compliance Questions

The Internal Revenue Service (IRS) instructed that plan sponsors should not answer the newly added compliance questions on the 2015 Form 5500 and Form 5500-SF since the new questions had not yet been approved by the Office of Management and Budget (OMB).

2016 Compliance Questions

In March 2016, the IRS announced proposed changes to the 2016 Form 5500 Series returns (including Form 5500, Form 5500-SF and 5500-SUP).  These changes incorporate updated/more consolidated versions of the 2015 compliance questions. Proposed questions include the following:

  • The trustee, custodian and Form 5500 preparer’s name and contact information
  • Basic information regarding methods used by qualified plans to satisfy nondiscrimination requirements, including ADP/ACP testing methods and minimum coverage
  • Timing of in-service distributions for plans subject to minimum funding including defined benefit and money purchase plans
  • Whether a plan received a favorable advisory, opinion or determination letter with related information
  • If required minimum distributions were made to more than 5% owners

The IRS also will provide a 2016 Form 5500-SUP that will be used to report these compliance questions to the IRS if these questions are not answered electronically on Form 5500 or Form 5500-SF. Form 5500-SUP will be a paper-only filing.

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