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Linda T. Fisher 5500 Consulting, LLC Newsletter
Keeping You Informed!
February 2012
Greetings!

Its hard to believe that February is already here.  Time flies when you're busy and having fun at it like we are. The 2011 Form 5500 schedules and instructions have been posted, and should be available from your software vendor now. In fact, we had to convert 10 years of pre-2009 filings from 2010 forms to 2011 and the software that we use (ftwilliam.com), did it automatically!! What a wonderful time-saver and surprise!  

 

We 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!
Did you miss any prior Newsletter issues? 
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We Can Assist With Training for the 2011 Plan Year!


Save time by turning the training task to us!
 

We know that effective Form 5500 training is hard to find. We can train your team on a variety of Form 5500 topics. Whether you have an experienced team that just needs to brush-up on current changes since last year, or you have new Form 5500 preparers that need the full training package, let us know. 
 
Is Schedule C still an area of confusion? We can assist with training that will get you on the right track! 
 
Are you a Form 5500 reviewer, but don't have a good understanding of how the certain schedules should coordinate with others? 
 
You and your people deserve to know more!  Click for more about our training offers! 
In This Issue
IRS Video - Form 5558
IRS Video - One Participant Plan Filings
Service Provider and Participant Disclosures
Popularity of Dogs in Advertising
IRS Will Not Accept >3 Plans Per Form 5558

The IRS has joined the video craze! They are creating videos on a variety of topics which they feel are important. Here is a Form 5500 related video that is linked from their "Form 5500 Corner" site to a Form 5558 page that has a link to the video.

This video stresses that they are serious about not accepting Form 5558 extension requests that attempt to  extend more than three Form 5500, 8955-SSA or 5330 filings. If they receive any like this, they will be sent back. So for all of you that have clients with a long list of filings, this means creating numerous Form 5558's. Hopefully software vendors will create a macro so conversion from an Excel spreadsheet onto numerous forms will be possible. 

Plan lists received by the IRS before July 31, 2012 will be returned and will not be processed. Lists received after July 31, 2012 will not be returned and will not be processed.

NOTE: So far, a signature is required to extend the Form 8955-SSA but at least one letter has been sent to the IRS, to hopefully eliminate this requirement soon.


IRS Encourages One Participant Plans to File 5500-SF
Another time-saving measure and improvement to accuracy for the IRS: They are encouraging one-participant plans to file on the Form 5500-SF, rather than on the 5500-EZ.  
 
Yes - this is highlighted on another IRS video.

To help encourage electronic filing for these plans, effective January 1, 2012, one-participant plan filings will not be available to the public through the EFAST2 Filing Search Application. Have you tried this out yet? Let us now whether it is true!

 

However, if you have any clients that missed their Form 5500-EZ filing requirement, they most likely cannot utilize the DOL's DFVC Program even though they can submit a Form 5500-SF. This is because one-participant plans do not have a filing responsibility with the DOL under Title I of ERISA. When the DOL receives a one participant plan on a Form 5500-SF, they forward it to the IRS. 
 
Has anyone submitted a late one-participant plan filing, on a Form 5500-SF or 5500-EZ in the past few years? If so, did the IRS send a $15,000 per year penalty letter? We have been told, they don't always send (or catch) these. 
 
Or was a Reasonable Cause letter submitted with the late filing(s) and honored by the IRS? Late Form 5500-EZ filings seem to occur often and there is not much information posted on the internet in regards to frustrations with huge penalty letters. Any experiences you have with this, would be helpful. Please send them to us at [email protected].  
Are You Ready for Participant Disclosures?
 

 

Here are a few items to note as the April 1, 2012 effective date approaches for DOL Reg. Sect. 2550.408b-2(c) 
 
Requires covered service providers to disclose compensation to the responsible plan fiduciary, effective April 1, 2012.

 

Participant Disclosures
Effective May 31, 2012 - Requires plan administrators to disclose information, including fee and expense information to participants. (Applicable for plan years beginning on or after Nov. 1, 2011)

 

  • The employer must disclose plan and investment costs to participants quarterly;
  • Must conform to DOL's model comparative charts: 
  • For a calendar plan year, disclosure must be distributed to participants by May 31, 2012 (60 days after the April 1, 2012 effective date.)
  • First quarterly statement of fees deducted must be furnished - August 14, 2012 (45th day after end of 2nd quarter).

 

12 Month Rule: Annual disclosure is required to be distributed once every 12 months (e.g. if you choose to distribute the second disclosure the following January 13, 2013 then the next one is required to be distributed by January 13, 2014.)

 

The annual statement sets up on what will be described in more detail on the quarterly statement. 

 

True or False?
  1. A primary reason why fee disclosure reporting requirements happened is because many Form 5500 filings do not have the 404(c) feature entered so the thought is that 404(c) requirements should apply to all plans.
  2. If the 408(b)(2) disclosures are missed by the April 1, 2012 deadline, you have a prohibited transaction.
  3. 408(b)(2) disclosures are not required if you just have brokerage options.
  4. When fees are paid from forfeitures and if forfeitures were not allocated to participant accounts then no disclosure on expenses to participants is required.

See Answers on our Facebook page! Like us on Facebook.


Popularity of Dogs in Advertising
Given the popularity of dogs and other pets, and with over 50 million households owning dogs, it is no wonder that the media continues to use them in advertising. The growing number of ads featuring dogs are designed to use their appeal to increase the favorable attitude toward the product or service featured.   

Some of the more common ads featuring dogs are for dog food companies, but it doesn't stop there. Dogs and other animals are commonly used in ads for cars, beer, soft drinks, carpet cleaning products, food, etc. Here is a favorite from the 2007 Super Bowl. 

Spot Dog float wink parade floats super bowl XLI commercial
Spot Dog float wink parade floats super bowl XLI commercial

 Enjoy all of the Super Bowl commercials, on game day and afterwards!

We would love to hear from you! Your comments and questions regarding this newsletter and future topics are important to us!
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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, LLC  has prepared and managed Form 5500 filings for 17 years and serves as a technical resource for fellow employee benefit plan professionals and plan sponsors that prepare their own filings. 
 
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.