Form 5500 reporting changes
for the 2009 plan year
The Department of Labor (DOL) has made significant Form 5500 changes and added reporting
requirements for the 2009 plan year. Vanguard has been diligently working on solutions and
implementing various process changes to accommodate these DOL requirements. And, while
Vanguard has been addressing our internal processes, plan sponsors still need to focus on the
action items noted below for the 2009 plan year.
Vanguard will continue to provide extensive regulatory filing support and guidance needed to
lessen the required reporting burden on our clients. More detailed information will be available
closer to the Form 5500 filing deadline.
What has changed
Description
Vanguard’s action
Plan sponsor’s (and authorized signer’s)
Action
Action date
Electronic filing
Form 5500, Schedules, and
Attachments (including audited
financials, if applicable) must be
submitted electronically through
the DOL’s ERISA Filing Acceptance
System 2 (EFAST2), available
1/1/2010. Form 5500-EZ, however,
must be filed in hardcopy format.
For clients who elect our Form 5500
preparation service:
Obtain unique filing
credentials (signature ID
and PIN), for authorized
signers from the DOL.
Schedule C, Service
Provider Information
Direct and Indirect
Compensation
Reporting
Schedule C of Form 5500 requires
disclosure of reportable compensation.
Large-plan filers* will be required to
report the identity of each person who
received direct or indirect compensation
of $5,000 or more.
Vanguard will enhance our current
software product to include Relius
Government Forms 5500 Web Client.
This enhancement will allow us to
work closely with plan sponsors to
gather the necessary data and assist
with the electronic filing process.
Vanguard’s 2009 Annual Plan-level
Financial Reporting Package will
include three new compensation
reports:
Administrative Expenses (direct fees
paid out of the plan), Redemption and
Purchase Fees (although most of these
fees need not be reported on Form
5500), and Indirect Compensation
(including non-monetary compensation:
Gifts & Entertainment and Conference
& Events). These new reports will
provide additional details to assist
plan sponsors to accurately report
compensation on the 2009 Schedule
C of the Form 5500.
Beginning
1/1/2010.
Collect disclosures
Beginning
from service providers
1/1/2010.
(other than Vanguard)
and fund groups that
are on Vanguard’s
recordkeeping platform)
that received direct or
indirect compensation
because of their
relationship with the plan.
Continued on next page . . .
What has changed
Description
Vanguard’s action
Plan sponsor’s (and authorized signer’s)
Action date
Action
Schedule C, Service
Provider Information
(See previous page)
Vanguard is requesting Form 5500,
Schedule C disclosures from outside
(non-Vanguard) fund companies, for
which Vanguard provides participant
recordkeeping services, to help
consolidate indirect compensation these
firms received. Vanguard will make
these disclosures available to affected
plan sponsors.
Collect disclosures
Beginning
from service providers
1/1/2010.
(other than Vanguard
and fund groups that are
on Vanguard’s recordkeeping platform)
that received direct or
indirect compensation
because of their
relationship with the plan.
Direct and Indirect
Compensation
Reporting
(continued)
Vanguard will provide a Form 5500
Indirect Compensation Disclosure Guide
of Vanguard funds that will be available
on the Vanguard Plan Sponsor Bridge®.
ERISA 403(b)
Plan Reporting
Plan sponsors of ERISA 403(b)
plans will be required to file a full
Form 5500 along with all financial
schedules. The annual reporting
requirement for ERISA 403(b) plans
will now be the same as for
401(k) plans. This includes the
requirement for an accountant’s
opinion for large-plan filers*.
Form 8955-SSA
(formerly Schedule SSA,
Annual Registration
Statement Identifying
Participants with
Deferred Vested Benefits)
Schedule SSA will no longer be
part of the Form 5500 filing beginning
with the 2009 plan year. This form has
been replaced with the Form 8955-SSA
and will need to be submitted to the IRS.
Form 5500 SF, Short
Form Annual Return/
Report of Small
Employee Benefit Plan
Form 5500-SF is a new form available
for the 2009 plan year for eligible plans
(generally, plans with fewer than
100 participants). This Short Form
is intended to simplify reporting
requirements.
*Large-plan filers are generally plans covering 100 or more participants.
Vanguard will provide certified annual
plan-level financial statements to
assist the preparer with much of the
data needed.
Form 5500 preparation service also
will be offered for plans for which
Vanguard is the single vendor and
the service is elected.
For clients who elect our Form 5500
preparation service:
Large-plan filers*
will need to identify
and engage a qualified
public accountant to
prepare the necessary
accountant’s opinion to
include with the
Form 5500.
Beginning
1/1/2010.
Complete Form 5500
will need to be prepared
and filed electronically
with the DOL.
Prior to the last
day of the 7th
month after the
end of plan year
(plus extension).
Mail paper copy to IRS
by due date.
Prior to the last
day of the 7th
month after the
end of plan year
(plus extension).
None
Beginning
1/1/2010.
Vanguard will prepare Form 8955-SSA
and post to the Vanguard Plan
Sponsor Bridge.
For clients who elect our Form
5500 preparation service:
Vanguard will use the simplified form
beginning with the 2009 plan year.
P.O. Box 2900
Valley Forge, PA 19482-2900
Connect with Vanguard® > institutional.vanguard.com > 800-523-1036
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All rights reserved.
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