Do you have a draft of a Wrap Plan Document for 2024 or an Amended DFVC filing for Form 2021? If yes, please read the following notes.
Wrap Plan Documents
If you need a Wrap Plan Document for a January 1, 2024 Plan year, the Wrap needs to be prepared and signed by the Plan Administrator by December 31, 2024. If this date is missed, the Wrap Plan Document cannot be backdated. The information below is from our ERISA Desk Team on this subject:
- If the intention is to wrap the benefits under one ERISA Plan for Form 5500 filing purposes, it is important that the Wrap Plan Document be signed (and thus officially adopted) by the Plan Sponsor on or before the last day of the ERISA Plan Year in which the Wrap is effective.
- For example, if a Wrap Document is to be effective for the January 1, 2024 to December 31, 2024 ERISA Plan Year, the plan sponsor would need to sign the plan document on or before 12/31/2024. This would enable the Plan Sponsor to file one Form 5500 filing for the 1/1/2024 – 12/31/2024 plan year that would be due 7/31/2025.
- To our knowledge, the DOL has not provided guidance on whether electronic signatures are acceptable for wrap documents. We recommend that the Wrap Plan Document have a wet signature on it and be placed in the Plan Sponsor’s files.
- Until the Wrap Plan Document is signed, the Wrap is technically not adopted and thus would not be usable to combine the benefits into one Form 5500 filing.
Important note: for Wrap Plan Document requests for a 1-1-24 effective date must be submitted and any outstanding questions must be answered by 12-1-24 for us to deliver the draft by the end of December.
For questions or to confirm your Wrap Document’s status, please contact the ERISA Desk team for assistance. They can be reached at ERISADeskInfo@ascensus.com. Several people read this email to provide a response as quickly as possible.
Amended or DFVC 2021 Form 5500s
If you have amended or late/DFVC 5500s prepared on Form Year 2021, those must be filed before December 31, 2024. If the date is missed, additional fees will be imposed to update those to the most current, 2024 Form Year.
Every year the DOL only allows three Form 5500 plan years to be used: Currently, this is the 2021, 2022, and 2023 Form Years. Starting on January 1, 2025, the Form Years roll forward and those that can be used are 2022,2023 and 2024. If we prepared for you a 2021 Form 5500 and it has not been e-filed yet, you have until 12/20/24 by Noon PST. Otherwise, we will need to redo the work to insert the data on the 2024 Form 5500. This will result in an additional fee.
If you have questions or need assistance on status, please contact Ann McAdam at amcadam@wrangle5500.com to line you up with the correct person to assist.