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DOL releases informational copies of 2015 Form 5500 Annual Return/Report

Schedules H, I, MB, SB being modified

Posted December 8, 2015

On December 3, the U.S. Department of Labor's Employee Benefits Security Administration, the Internal Revenue Service, and the Pension Benefit Guaranty Corporation released advance informational copies of the 2015 Form 5500 annual return/report and related instructions. The “Changes to Note” section of the 2015 instructions highlight important modifications to the Form 5500 and Form 5500-SF:

  • New IRS Compliance Questions were added to Schedules H and I (Lines 4o, 4p, 6c, and 6d ) and Schedule R (Part VII), and to the Form 5500-SF (Lines 10j, 14c, 14d, and Part IX) for purposes of satisfying the reporting requirements of section 6058 of the Code. However, these new IRS compliance questions are optional for the 2015 plan year. The Schedule MB instructions are modified to add RP-2000 and RP-2000 (with Blue Collar Adjustment) to the list of mortality tables for non-disabled lives that plans may report in line 6c. The Schedule MB and instructions are also modified to add a new question in line 8b that would require large multiemployer plans (500 or more total participants as of the valuation date) to provide in an attachment a projection of expected benefit payments to be paid for the entire plan (not including expected expenses) for each of the next ten plan years starting with the plan year to which the filing relates. The Schedule MB is modified to require all multiemployer plans to report the funded percentage for monitoring the plan’s status in line 4. Previously, only plans in critical or endangered status were required to report this information. As a result of the Multiemployer Pension Reform Act of 2014, the Schedule MB and instructions are further modified to extend the reporting requirements in line 4 for multiemployer plans in critical status to plans in critical and declining status and require that additional information to be reported by plans that have been partitioned or have had benefits suspended.
  • The Schedule SB instructions are modified to simplify the alternative age/service scatters that cash balance plans with 1,000 or more active participants have an option to report on an attachment to line 26.
  • The instructions for “Final Return/Report” are modified to add a statement that a filer for a terminated defined benefit plan for which PBGC has been appointed trustee may contact DOL at for further information.

The advance copies of the 2015 Form 5500 are for informational purposes only and cannot be used to file a 2015 Form 5500 annual return/report. Pension and welfare benefit plans that are required to file an annual return/report regarding their financial conditions, investments and operations each year generally satisfy that requirement by filing electronically the Form 5500 or Form 5500-SF and any required attachments under the all electronic EFAST2 system for submission, receipt, and processing of the Form 5500 and Form 5500-SF.

Informational copies of the forms, schedules, and instructions are available online at The DOL recommends 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.

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