Advance Copies of 2019 Form 5500 Released

The Department of Labor’s Employee Benefits Security Administration (EBSA), the IRS and the Pension Benefit Guaranty Corporation have released advance copies of the 2019 Form 5500 and the Form 5500-SF, as well as their schedules. They will be used for reporting information pertaining to the 2019 plan year.

The advance copies are informational only — they are not to be used for reporting and filing. Copies that can be used for actual filing will be released later.

What’s New for 2019 Reporting

The agencies have made the following changes to the form and schedules for 2019 reporting:

• Administrative Penalties: The instructions have been updated to reflect an increase to $2,194 per day in the maximum civil penalty amount assessable under ERISA Section 502(c)(2), as required by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. The increased penalty under section 502(c)(2) is applicable for civil penalties assessed after Jan. 23, 2019, whose associated violation(s) occurred after Nov. 2, 2015.
• Form 5500, Line 2d: The instructions to line 2d of the Form 5500 have been clarified concerning how to report the plan sponsor's business code for multi-employer plans.
• Schedule H Part III- Accountant's Opinion: The instructions for lines 3a(1), 3a(2), 3a(3), and 3a(4) have been revised to align with the language in the clarified generally accepted auditing standards, AU-C 700, Forming an Opinion and Reporting on Financial Statements and AU-C 705, Modifications to the Opinion in the Independent Auditor's Report.
• Schedule SB Mortality Tables: Line 23 has been revised to eliminate mortality table options that are not available after 2018.
• Schedule R: A new line 20 has been added to obtain information related to PBGC reporting requirements resulting from unpaid minimum required contributions. Only PBGC-insured single-employer plans are required to provide this additional information.
• Form 5500-SF: A new line 11b has been added to the Form 5500-SF that parallels the new Schedule R, line 20 for PBGC-insured, single-employer plans that file the Form 5500-SF instead of the Form 5500.

Additional information, as well as copies of the forms, schedules and instructions are available here.