Starting on January 1, 2021, the Department of Labor (the DOL), as well as the IRS, will only accept two active Form 5500 versions for e-filing: the 2019 and 2020 versions. For current filers, this has no impact. However, if the Plan Sponsor had the need to amend a 5500 for Plan Years prior to 2019, or needed to use the DOL’s Delinquent Filer Voluntary Compliance (DFVC) program, older Form versions, starting with 2018, will not be accepted. For example, if the Plan Sponsor needs to file an amended 2018 Form Year 5500, it will need to be submitted on the most current 2020 Form Year.
In the past, the DOL allowed older Form versions from the last four years to be considered active. This will no longer be the case.
Here are examples to help clarify:
- DFVC filing currently prepared and ready to be signed on a 2018 Form 5500: If not e-filed by December 31, 2020, Wrangle will need to redo the 2020 Form 5500.
- Plan year is 7/1/2019 – 6/30/20: The 2019 Form has been prepared and is due on 1/31/2021. Using the 2019 Form is correct.
Wrangle’s Response:
This decision is a significant change from an approach that the DOL has taken for many years. However, Wrangle’s proprietary software, available to you through the online Dashboard, can immediately adopt the new protocol.
Wrangle’s approach stems from one core value: We see our broker and clients as genuine partners. We have and always will be a service company, and our focus is to ease the burden of reporting.
If you have any questions on this matter, need assistance on Form 5500s to e-file, or anything else, please don’t hesitate to contact Ann McAdam at amcadam@wrangle5500.com.