The Plan Number of the ERISA Plan and the Plan Sponsor’s EIN are critical information reported on the Form 5500. Together, they form a specific identifier for the DOL and IRS to track the ERISA Plan from the onset and legacy period. Please keep in mind that key identifiers, such as the EIN and Plan Number, match the ERISA Plan Document.
Issue: Incorrect Plan Number Reported
(Per verbal direction from the DOL)
- Option 1: Amend and re-file the Form 5500 for the impacted plan years filed. This represents a conservative, low-risk approach. Wrangle will utilize Question 4 on page two of the Form 5500 to note the Plan Number that was previously reported and list the correct Plan Number on page one of the amended filing.
- Option 2: Amend and re-file only the most recent Form 5500. That approach may result in questions from the DOL.
With either approach, a letter that provides more detail and an explanation of why the Plan Number changed is recommended to be attached. Presumably, that explanation would include that the Form 5500 was being amended to match the ERISA Plan Document.
Issue: Plan Number Updated Within the ERISA Plan Document
- If the Plan Number changes from one year to the next due to an amendment to the ERISA Plan Document, then the Form 5500 for the plan year prior to the change needs to file a final Form 5500. If a final Form 5500 was not filed, an amended filing should be completed to indicate a final filing.
- The Form 5500 for the plan year in which the Plan Number change took effect should be filed as a first filing.
Example:
If the Form 5500 was filed with a Plan Number of 504 in 2025 and changed to 505 in 2026:
- File a final Form 5500 for Plan 504 for the 2025 plan year.
- File a first Form 5500 for Plan 505 for the 2026 plan year.
Best Practice:
Consult an ERISA attorney before finalizing any changes to ensure compliance and determine the appropriate course of action.
For questions or more information, please contact Ann McAdam at info@wrangle5500.com.