[9256]
September 18, 1997
TO: PENSION COMMITTEE No. 34-97
PENSION OPERATIONS ADVISORY COMMITTEE No. 35-97
RE: TREASURY, DOL AND PBGC ISSUE PROPOSED NEW FORM 5500 PACKAGE
______________________________________________________________________________
On September 2, the Treasury Department, Department of Labor and the Pension
Benefit Guaranty Corporation jointly issued a proposed new Form 5500 package that includes
revised forms, with revised instructions, that pension, welfare and fringe benefit plans must file
with the various Agencies. The three Agencies worked together to simplify and streamline the
annual reporting requirement and to reduce the filing burden for plan sponsors. Under the
proposed Form 5500, both large and small plans would use the same Form 5500 for filing
purposes. The Agencies also restructured the Form 5500 to more closely resemble corporate
and individual tax returns. The revised Form 5500 consists of a one-page main form containing
basic plan identifier information and a checklist indicating additional forms included with the
filing.
The Agencies added five new schedules to the Form 5500 package and revised three
existing schedules. Five schedules remain unchanged. The new filing schedules are:
Schedule D, Direct Filing Entity/Participating Plan Information -- used to file
information on relationships between plan and master trust accounts,
common/collective trusts, insurance company pooled separate accounts, certain
investment entities and group insurance arrangements;
Schedule FIN, Financial Information -- incorporates financial statements from the
current Form 5500 and adds questions concerning investments, financial
transactions and plan assets;
Schedule FIN-SP, Financial Information for Small Plans -- maintains simplified
financial statements under the current Form 5500-R and adds a number of specified
investment categories;
Schedule PEN, Pension Plan Information -- used to report information on
participant coverage, plan distributions and funding for qualified and non-qualified
pension plans that file Form 5500; and
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Schedule Q, Qualified Pension Plan Coverage Information -- used for plans during
the first year of the three-year testing cycle under Revenue Procedure 93-42 or
annually for plans not in the three-year testing cycle.
Although most of the Schedule A, Insurance Information, data collection requirements
are unchanged, the schedule was revised to conform to recent accounting industry changes on
current value financial reporting of investment-type contracts with insurance companies.
Revised Schedule C, Service Providers Information, would be limited to the 40 top-paid service
providers at or above the $5,000 threshold for compensation paid by a plan during the plan
year and limit explanations for service provider terminations to accountants and enrolled
actuaries. Plans would also no longer be required to file a Schedule C to identify plan trustees
annually. Plans that complete lines 27b, 27c, 27e, and 27f of the current Form 5500 would be
required to file Schedule G, Financial Transaction. The Agencies did not revise Schedule B
(Actuarial Information), SSA (Separated Participants with Deferred Vested Benefits, Schedule F
(Fringe Benefit Plan Information), Schedule E (ESOP Annual Information), or Form 5500-EZ,
applicable to business owners and their spouses.
Comments on the proposed Form 5500 are due to the Department of Labor by
November 3, 1997. A joint public hearing will be held November 17 and, if necessary,
November 18, 1997 at 10:00 a.m. at the Department. If you have any comments on the proposed
Form 5500 package, please forward them to us by Friday, October 17, 1997. We will keep you
informed of developments.
Kathryn A. Ricard
Assistant Counsel - Pension
Attachment (in .pdf format)