There will be some differences this year, of course, including some additional disclosures on Schedule C, and a mandate on electronic filing of this information for the first time.
This week I asked readers about their experiences with the filing, and what, if any, surprises came up.
Now, it could be the heat (see SURVEY SAYS: How Hot Is It?), the fact that some are still out on holiday (and others not “out”, but in holiday mode – see SURVEY SAYS: When Will You Be Closed for the Fourth?), or even that the question is a bit complicated – but the response rate was a bit lower this week than normal.
That said, regardless of response volumes, time and again these surveys have, thanks to you, proven to be directionally accurate, if not downright prescient.
First off, only one-in-eight of this week’s respondents have completed the 2009 plan year filing, and roughly 40% of this week’s respondents said they hadn’t yet completed the form (among them a respondent who said, “We file extensions every year”). Of the remaining respondents, 28% work with plan sponsors who file that form (though, as you’ll see, they had some interesting insights), 16% said they have no direct involvement with the filing, and the rest said their plan isn’t required to file that form (public sector plans, mostly – as one reader noted, “Ah, the beauty of working on governmental plans – no 5500’s!!”).
However, some who had tried hadn’t (yet) been successful. One reader noted “I electronically filed but it bombed as our provider got an error message. So now waiting on them so I can refile”.
Now, as noted above, one of the differences this year is the requirement that the forms be filed electronically – and I asked readers how they felt about that new process.
Among those who had completed the filing, roughly 40% said they liked the process (though among these was a reader who said “Except that it didn't work.”), another 40% found it to be “pretty painless”, and the remaining 20% said they found it to be a bit confusing. Among those the reader who noted, “I kept getting access to different areas confused and always seemed to be using the incorrect process.”
One provider noted “I can now recite the steps to filing in my sleep after walking several hundred clients through it. It's a shame so many clients never learned to read instructions....”
There’s that old adage equating being out of “sight” to being out of mind – and with the advent of electronic filing, I wondered (and asked) if readers thought the electronic filing had in any way diminished or impacted their review of the information. Roughly two-thirds (63.2%) said the information received the same level of scrutiny as in previous years, while 5.3% said they reviewed it more carefully.
Maybe it’s just been a long time, but a full one-in-five weren’t sure, while the remaining 10% were still in the process of dealing with the information (including one reader who said, “Plan to apply same level of review; however, have done more front-end research on changes than usual”).
As for the oft-fretted new fee disclosures on Schedule C – well, based on our sampling, it may have been much ado about nothing (or perhaps it will be “nothing” because much ado was made about it early on).
Of those who had gotten to the form, nearly half (44.6%) said there was nothing there of which they weren’t already aware, and more than one-in-five (22.3%) said they “didn’t really notice much difference.”
Of the rest, roughly one-in-eight said that they saw some numbers that they are questioning (one reader noted, “We found some information that should have been deleted from the plan a few years ago and was still there. It will now be taken care of”), about 11% acknowledged that it has raised some concerns, and the rest – well, they admitted they hadn’t really focused on it yet.
One reader noted, “Very confusing schedule. Glad I attended a seminar where it was explained in detail. Can't imagine how much time I would have wasted on it otherwise.”
Among the verbatim comments this week were these insights:
“Get to try out the e-filing on health & welfare plans first. Hope it prepare me for the more complicated pension plans filings.”
“After the first year, it will be much ado about nothing.”
“It was fairly painless...it still took more time to complete than in previous years. Time effort will probably lessen in the future. The "signing ceremony" is bogus.”
“Our experience as recordkeeper is that while we have prepared and made available most of the 5500 filings we prepare, few plan sponsors have viewed, much less filed the 5500. Of those that have, our biggest surprise is even after sponsors have received their credentials, they seem to be very confused on signing the form. Many sponsors are receiving errors requiring amended filings to correct their signature.”
But this week’s Editor’s Choice goes to the reader who said that “a similar survey should probably conducted in August, and after October 15.”
Thanks to everyone who participated in our survey! Readers interested in more information on the "new" Form 5500 filing process can find a list of resources on the next page.
Readers interested in more information on this year’s filing process may find the following helpful:
DoL Adds EFAST2 Info at http://www.plansponsor.com/DoL_Adds_EFAST2_Info.aspx
EFAST2 Adds Signature Option at http://www.plansponsor.com/EFAST2_Adds_Signature_Option.aspx
For 403(b) Plans:
EBSA Offers Form 5500 Guidance for 403(b) Plans at http://www.plansponsor.com/EBSA_Offers_Form_5500_Guidance_for_403b_Plans.aspx
FROM THE DOL: