No Need to Answer New Form 5500 Compliance Questions

The big news after the Internal Revenue Service (IRS) released the Form 5500 for the 2015 plan year was the addition of compliance questions. 

Answering them was “optional,” the IRS said at the time, “but we strongly encourage you to answer them.” The questions ask for information about how retirement plans satisfy discrimination testing, methods for testing requirements, if the ADP or ACP test is used, and the timeliness of plan amendments.

However, now the IRS has changed its stance, telling plans not to answer the questions.

Instructions released by the IRS say, “New Part VII (IRS Compliance Questions) was added to Schedule R for purposes of satisfying the reporting requirements of section 6058 of the Code. The IRS has decided not to require plan sponsors to complete these questions for the 2015 plan year and plan sponsors should skip these questions when completing the form.”

In addition, regarding new financial information reporting on the Form 5500, the IRS says, “New Lines 4o, 4p 6c, and 6d were added to Schedules H and I. The IRS has decided not to require plan sponsors to complete these questions for the 2015 plan year and plan sponsors should skip these questions when completing the form.”