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Linda T. Fisher 5500 Consulting, LLC Newsletter
Keeping You Informed!
December 2011
Greetings!

Welcome to our newly formatted Linda T. Fisher 5500 Consulting, LLC Newsletter! We will continue to provide Form 5500 related government updates in addition to providing helpful articles. We know that you likely have more responsibilities than just Form 5500 preparation, so to keep you in the loop, we are providing 5500 related guidance directly to you! Stay tuned each month to learn about:

  • Solutions to Common Errors;
  • Dept. of Labor and IRS Updates;
  • Specific Schedule Guidance; and 
  • Training Offerings!
Pass this along to others that will benefit!! 
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In This Issue
Welcome!
PBGC Expense Reporting - Schedule H Clarified
Form 8955-SSA Participant Statements
An Unforgettable Story - Pay it Forward
PBGC Expense Reporting on Schedule H -  Clarified / Corrected
Did you notice in the 2009 and 2010 Schedule H instructions the change regarding reporting of PBGC premiums payments? We did and it did not sound right. Now the PBGC recently announced this instruction error.
   

 

On November 2, 2011, the PBGC responded to an inquiry by the Pension Committee of the American Academy of Actuaries about the Schedule H instructions that directed us to report DB Plan PBGC premium payments on the "Transfer Out" line rather than as a plan expense.   Both the 2009 and 2010 instructions directed filers to report PBGC premiums paid from plan assets on line 2l: "Transfers Out" which in the past was only to be used for plan-to-plan transfers. 

 

New guidance states that PBGC Premiums paid from plan assets, for the 2009 and 2010 plan years may be reported on either Line 2(i)(4) (other administrative expenses) or Line 2l (transfers of assets)."  For 2011 plan years, filers will be required to report that information on Line 2(i)(4).  


By issuing this announcement, the PBGC is saying that they do not want you to go back and amend the 2009 and/or 2010 Schedule H just because you followed the erroneous instructions. 
Form 8955-SSA Participant Statements

There has been a lot of discussion and confusion around what is required in regards to the new question (Line 8) of the IRS' Form 8955-SSA that asks whether a participant statement was furnished to each affected participant that reports the information reported on the form. A penalty of $50 will be charged for each willful failure to furnish the statement or a false statement. 

 

Though this issue was verbally addressed by the IRS at the October 2011 Annual ASPPA conference, we have not seen anything from them in writing, as of December 9, 2011.

 

Therefore, stay tuned for more on this topic. In the meantime, as long as there is not a refusal by the person required to provide a statement to each term vested participant, that outlines their qualified plan benefit, you should be okay until the IRS clarifies this requirement. 

 

Questions around the statement requirement include whether the full Social Security Number (SSN) that is reported on the Form 8955-SSA, will be required on each participant statement. Another concern is whether the actual 8955-SSA Codes A, B, C, D need to be on each statement, or just the type of benefit they are entitled to.  

 

Other Form 8955-SSA Updates:

  • IRS will allow 2010 SSA information to be reported on the 2009 form (but not a preferred approach since the 2010 form has been issued);
  • Since a Transmitter Control Code (TCC) is required for Form 8955-SSA electronic transmission, ensure your 5500 software vendor will handle this on their end;
  • A single TCC can only be used for up to 999 plans in a single year (not 9,999 as indicated on IRS website); and
  • Each plan's SSA must be submitted individually (cannot submit in batch with other plans).

NOTE: The IRS FIRE site will be down for scheduled maintenance starting at 6 PM ET on December 16, 2011 through January 3, 2012. 

An Unforgettable Story - Pay it Forward
The Simple Truths of Service: Johnny the Bagger
The Simple Truths of Service: Johnny the Bagger

A friend of mine, Ken Varga, sent me this video and I was so impressed with the message that I would like to share with you what I believe to be the most cost effective and creative way to make your business stand-out from the others. Just click on the arrow to watch.

 

Since I watched it, I think about it often.  Not only does it bring service into perspective, it brings life into perspective.

 

Don't forget to pay it forward, by sharing this with friends, family, and co-workers. They'll thank you for it!

 

Let me know your thoughts after watching the video. Also let us know how it has helped you and your business.

We would love to hear from you! Your comments and questions regarding this newsletter and future topics are important to us!
Click here to provide your feedback!
 
Sincerely,
 

Linda Fisher
Linda T. Fisher 5500 Consulting, LLC
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Our Mission
Linda T. Fisher, owner of Linda T. Fisher 5500 Consulting, for 16 years has prepared and managed Form 5500 filings for 17 years and serves as a resource for Form 5500 related questions. 
 
She is fully aware that as employee benefit laws change, plan sponsors become confused about their filing requirements. 
 
Our mission is to educate all those involved with Form 5500 preparation and review. We do this through our preparation services, offering training programs for both preparers and reviewers, along with 'as needed' coaching.