ICI Comment Letter on Annual Report/Return of Employee Benefit Plan (Form 5500)
[27619]
October 2, 2013
TO: PENSION MEMBERS No. 48-13OPERATIONS COMMITTEE No. 50-13
BANK, TRUST AND RETIREMENT ADVISORY COMMITTEE No. 35-13
TRANSFER AGENT ADVISORY COMMITTEE No. 74-13 RE: ICI COMMENT LETTER ON ANNUAL REPORT/RETURN OF EMPLOYEE BENEFIT PLAN (FORM 5500)
The Institute submitted the attached comment letter to the Internal Revenue Service (IRS) responding to IRS’s request for comment under the Paperwork Reduction Act on the usefulness and burden of the Form 5500 information collection. [1] The Institute’s letter focuses on the Form 5500 Schedule C and discusses the current Schedule C “eligible indirect compensation” disclosure requirements, as well as the current 408(b)(2) service provider disclosure requirements. The letter recommends that IRS coordinate with the Department of Labor (DOL) to harmonize the requirements of Schedule C of Form 5500 with the 408(b)(2) regulation. This is consistent with the Institute’s recommendation in an August, 2010 comment letter submitted to DOL in response to a prior DOL Form 5500 information collection request. [2]
Howard Bard
Associate Counsel
endnotes
[1] IRS’s request for comment is available here: www.gpo.gov/fdsys/pkg/FR-2013-07-29/pdf/2013-18084.pdf.
[2] See Memorandum to Pension Members No. 34-10, Bank Trust and Recordkeeper Advisory Committee No. 27-10, Operations Committee No. 22-10, Transfer Agent Advisory Committee No. 48-10 [24501], dated August 19, 2010.