Advance 2016 Form 5500 Released

By John Iekel • November 02, 2016 • 0 Comments
Advance copies of the 2016 Form 5500 and Form 5500-SF are now available. The IRS, Department of Labor (DOL) and Pension Benefit Guaranty Corporation (PBGC) released the advance copies on Nov. 1.

It is important to note that the advance copies are for information purposes only — they are not to be used for actual reporting or filing. The release of the advance copies of the forms does, however, give Form 5500 and Form 5500-SF filers an early look at the information that they will need to provide about the 2016 plan year and enhances their ability to gather the necessary information in order to file in a timely manner.

Key Changes

Following are the key changes made to the Form 5500 and Form 5500-SF for reporting about 2016.

IRS Compliance Questions. Although they appear on the 2016 Form 5500, Form 5500-SF, Schedules H, I, and R, the IRS has decided that filers:

  • should not enter the Preparer’s Information at the bottom of the first page of Form 5500 for the 2016 plan year;

  • should not answer the IRS questions at Lines 4o and 6a through 6d of Schedules H and I; and

  • should not answer the ‘Part VII — IRS Compliance Questions’ of the Schedule R.

Similarly, filers that are using the Form 5500-SF to satisfy their annual reporting requirement:

  • should not complete the ‘Preparer’s Information’ at the bottom of the first page, ‘Part VIII —Trust Information’; and

  • should not complete ‘Part IX-IRS Compliance Questions’ on the Form 5500-SF.

Filers should skip these questions when completing the forms.

Administrative Penalties. The instructions have been updated to reflect an increase in the maximum civil penalty amount assessable under ERISA Section 502(c)(2), required by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. DOL regulations published on July 1, 2016 increased the maximum penalty to $2,063 a day for a plan administrator who fails or refuses to file a complete or accurate Form 5500 report. The increased penalty under section 502(c)(2) is applicable for civil penalties assessed after Aug. 1, 2016 for associated violation(s) that occurred after Nov. 2, 2015, the date the 2015 Inflation Adjustment Act was enacted.

Schedules H and I. Line 5c is modified to add a new question. The existing Line 5c question asks, if a plan is a defined benefit plan, whether it is covered by the PBGC insurance program. The new question asks filers that answered “yes” to enter the My PAA-generated confirmation number for the PBGC premium filing for the plan year.

Schedule SB. The instructions for CSEC plans, reported in Line 27, Code 1, have been updated to reflect guidance on certain issues relating to the application of the Cooperative and Small Employer Charity Pension Flexibility Act.

Forms and Schedules Modified

The forms and schedules that have been updated include:

  • Schedule D — DFE/Participating Plan Information

  • Schedule I — Financial Information — Small Plan

  • Schedule MB — Multiemployer Defined Benefit Plan and Certain Money Purchase Plan Actuarial Information

  • Schedule SB — Single-Employer Defined Benefit Plan Actuarial Information


The agencies suggest that filers monitor the EFAST website for the availability of the official electronic versions for filing using EFAST-approved software or directly through the EFAST website.