Targeting Retirement Plans
The Department of Labor’s Office of the Chief Accountant has begun an initiative to detect plan sponsors currently not filing their welfare plan Forms 5500. “Request for Clarification of Your Welfare Benefit Plan Annual Reporting Requirements” emails and letters have started being sent to plan sponsors who filed a Form 5500 for their retirement plan, but did not file for a health and welfare benefit plan. Specifically, we believe the DOL is targeting retirement plans with 100 or more employee participants. Generally, health and welfare benefit plans are required to file a Form 5500 if there are 100 or more employee participants in the plan as of the beginning of the plan year.
The DOL is giving plan sponsors 15 days to respond to the requests. Plan sponsors who find themselves with delinquent filings are encouraged to file using the DOL’s Delinquent Filers Voluntary Compliance (DFVC) Program. To determine if your health and welfare plan is subject to the filing requirements, see our “Welfare Plan Issues and Electronic Filing Information” page or contact one of our 5500 Experts to evaluate your particular situation. We will be ready to assist you in responding to the request and bringing your plans into compliance.