Annual plan reporting services for 403(b) clients:
Frequently asked questions
Q. What has changed with regard to the Form 5500 for the 2009 plan year?
A. Effective for the 2009 plan year, employee benefit plans under section 403(b) of the Internal
Revenue Code that are covered under the Employee Retirement Income Security Act of
1974 (ERISA) are required to file a complete Form 5500, all applicable schedules, and (for
large plans) an audit report. In addition, all Form 5500s must be filed electronically using
the Department of Labor’s (DOL) ERISA Filing Acceptance System 2 (EFAST2) program.
Beginning with the 2009 plan year, the Form 8955-SSA (previously know as Schedule SSA)
will require separate filing with the IRS. The deadline remains the same.
Plan sponsors should review the DOL’s new reporting and independent audit requirement
for 403(b) plans covered under ERISA. The DOL has developed a new webpage dedicated
to 403(b) plan compliance that includes links to additional resources for Form 5500
reporting and filing requirements (www.dol.gov/ebsa/403b.html).
Q. What does the audit requirement mean for plan sponsors?
A. Generally, if your plan has 100 or more participants at the beginning of the plan year,
you must make arrangements to have the plan’s financial statements audited by an
independent auditor. The auditor will provide a signed audit opinion with the audited
statement. These audited financial statements will need to be transmitted to the DOL
along with the final Form 5500.
Please reference the Vanguard Plan Sponsor Bridge®, Compliance Corner, for additional
information related to electronic filing.
Q. What information will my auditor need?
A. The auditor will need plan year financial information from each vendor that provides service
to the 403(b) plan(s). If your plan meets the requirements to have an independent audit,
you will also need to include comparative financial information as of plan year-end 2008.
Please consult with your individual auditor to determine if additional data is required.
Q. How does Vanguard provide this information?
A. Vanguard Compliance and Annual Plan Reporting Services (CAPRS) prepares annual
plan-level financial reporting packages for every ERISA plan. This package includes:
Includes Certification of Accuracy, Balance Sheet, Income Statement,
Annual Activity by Fund, Supplemental Information, attachments used for Schedule H
of Form 5500 filing, Participant Count and Form 8955-SSA (Schedule SSA) information,
and other reconciling statements.
• Annual Report:
• Annual Plan Financial Report (PFR):
System-generated PFR detailing the activity during
the plan year.
• 5% Detail Report:
Details the purchases and sales for each fund during the plan year.
• Amounts Forfeited Report:
Details amounts forfeited during the plan year, by participant.
• Contributions by Source Report:
Provides contributions posted to each source during
the plan year.
Provides contributions for each participant, detailed
by fund and source, during the plan year.
• Contributions by Participant Report:
Provides details on individual participant loans held as of the end
of the plan year (if applicable).
• Detailed Loan Report:
• Distributions Report:
• Rollovers Report:
Details all distributions taken during the plan year, by participant.
Details all rollovers received during the plan year, by participant.
• Participant Gain-Loss Detail Report:
Details participant activity throughout the year.
Q. How can Vanguard help determine the participant count if the plan has more than
one vendor?
A. The participant count included in the Annual Report reflects the number of participants
who have an active status in our system. Because participants may choose to maintain
accounts with more than one vendor in the plan, it is not recommended that you add
the numbers received from the various vendors. Your Vanguard relationship manager
can provide a more detailed report if necessary.
Q. When will the plan’s financial reporting package be available?
A. For plans with a year-end date of December 31, the Annual Plan-Level Financial Reporting
package will be available by April 30. Please contact your relationship manager if you have
any questions about the package release date.
Q. How can I access the Annual Plan-Level Financial Reporting package?
A. The package is posted to the Vanguard Plan Sponsor Bridge. Given the sensitivity of the
data included in each package, this is the most secure and reliable method of distribution
and storage.
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Q. How will my auditor access the Annual Plan-Level Financial Reporting package?
A. Consistent with Vanguard’s data delivery policy, auditors will be required to access the
Annual Plan-Level Financial Reporting via the Vanguard Plan Sponsor Bridge. Please contact
your internal Bridge security administrator or your client relationship administrator to obtain
access to the Annual Plan Reporting page on the Bridge.
Q. What is “good faith” transition relief?
A. The DOL expects administrators of 403(b) plans to make good faith efforts to transition
for the 2009 plan year to ERISA’s generally applicable annual reporting requirements (DOL
Field Assistance Bulletin Nos. 2009-02 and 2010-01). Acknowledging that there may be
instances when full annual reporting compliance by 403(b) plans may not be possible for
the 2009 plan year, the DOL has stated that the guiding principle must be to ensure that
appropriate efforts are made to act reasonably, prudently, and in the interest of the plan’s
participants and beneficiaries.
Q. Will Vanguard prepare Form 5500 for my plan?
A. Vanguard’s Form 5500 preparation service is available to single-vendor clients. Please contact
your relationship manager for further details.
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P.O. Box 2900
Valley Forge, PA 19482-2900
Connect with Vanguard® > institutional.vanguard.com > 800-523-1036
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