A slim update to Form 5500, Annual Return/Report of Employee Benefit Plan, makes a handful of changes to reporting for defined benefit (DB) plans and defined contribution (DC) multiple-employer plans (MEPs). However, the update defers the bulk of last year’s broader package of proposed revisions and amended supporting regulations. The final changes — including a new 50-year benefit projection for single-employer DB plans — are effective for 2022 plan-year reporting. The Department of Labor (DOL), IRS, and the Pension Benefit Guaranty Corp. (PBGC) are continuing to review the many comments on other aspects of last year’s proposal for possible implementation in future years.
The updated instructions include two changes to Schedule SB, Single-Employer Defined Benefit Plan Actuarial Information:
Multiemployer plans will see several changes to Schedule MB, Multiemployer Defined Benefit Plan and Certain Money Purchase Plan Actuarial Information, along with revised instructions that clarify existing requirements. Significant changes include:
In addition, the requirement on Schedule R, Retirement Plan Information, to provide identifying information about any participating employer that contributed more than 5% of the plan’s total contributions will expand to include the 10 highest-contributing participating employers.
For Schedules SB and MB, plans can opt to provide certain attachments reporting tabular information in a spreadsheet rather than as a PDF or text file:
A few minor changes apply to the 2022 Form 5500 and Form 5500-SF instructions for DC MEPs, including pooled employer plans (PEPs). These changes include new plan characteristic codes to identify different types of DC MEPs and to clarify which entities to identify as plan sponsors and plan administrators.
Last year’s expansive proposal included a series of changes — several implementing provisions of the Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019 (Div. O of Pub. L. No. 116-94) — not covered by either of the two recent final updates:
The agencies say they need additional time to consider the comments received and coordinate changes with the contractual development schedule for updates to the EFAST2 electronic filing system. As a result, these outstanding items won’t be finalized for 2022 plan year reporting and instead will be addressed in either a separate final regulation or the broader Form 5500 modernization proposal on DOL’s latest regulatory agenda.