(b)lines Ask the Experts – Delaying Form 5500 Reporting

July 9, 2013 (PLANSPONSOR (b)lines) - "As I was enjoying the July 4th Holiday, I found myself waxing nostalgic for the days when I would be filing our 5500 annual report for our Employee Retirement Income Security Act (ERISA) 403(b) plan this time of year (our plan year is calendar).

“Now, with audits and such, it seems that we are always extending the filing deadline to October 15. I am not a procrastinator by nature, and the filing now comes during a busy period as we are working on our annual open enrollment for all of our benefits. Is it possible to file the form earlier even with an audit? Is everyone else waiting for October as well?”  

Michael A. Webb, Vice President, Retirement Plan Services, Cammack LaRhette Consulting, answers:

The Experts emphasize with you, as we are not procrastinators, either!  And indeed, prior to 2009, there was no reason to delay, since 403(b) plan sponsors were required to answer only a handful of questions, many entities filed their forms well before the July 31 deadline for calendar year plans.

However, audits do indeed take several months to complete, and the experience in the corporate world, where audits of 401(k) and other qualified plans have always been required, is that most plan sponsors extend their time to file until October 15. The reason audits can be lengthy is that not only must vendor financials be meticulously reviewed, but payroll records as well.

Given the length of the audit process, must you and other plan sponsors wait until the last minute to file? Not necessarily. Touch base with your auditor; explain that you would like to file as early in the year as possible. The Experts suspect the auditor will be able to provide suggestions as to action steps you can take on your end to ensure the process is completed in as an efficient fashion as possible. The Experts can make no promises of a return to the good old days of July filings, but perhaps the completed return and audited financials can be filed sometime prior to your busy open enrollment period.

Even if that is not the case, the Experts would suggest you NOT wait until the absolute last day to file. If you discover something is wrong at the last minute, there is no time to correct. And, as with all websites, the EFAST website processing speed may be affected by the heavy traffic to the site that likely takes place nears filing deadlines.

Good luck with enhancing the speed of your process, and the Experts hope that you (and all of our readers) had a wonderful Independence Day!


NOTE: This feature is to provide general information only, does not constitute legal advice, and cannot be used or substituted for legal or tax advice.