The October 15 deadline has passed and your 12/31 plan year Form 5500-SF or full Form 5500 with the IQPA is filed. Congratulations! But, What's Next?
First, take a breath. You've filed on time and avoided any potential late penalties, which can be quite significant. How significant? Well, "a penalty of up to $2,194 a day for each day a plan administrator fails or refuses to file a complete and accurate report" is certainly significant enough for us.
Next, review some of the top "To-Dos" here to stay on track post-filing your return.
Top Post-5500 Filing Items
1. Review Your Cash-Out Provisions & Terminated Participant Accounts
Your retirement plan may have a mandatory distribution provision with a $1,000 or $5,000 threshold. This provision allows you to force out terminated participants that have small balances in your plan. As a fiduciary, you are responsible for all plan participant account holders, actively employed and terminated. The cash-out provision provides you a means to transfer balances out of the plan to avoid potential issues later on that can arise from locating lost participants.
A good exercise would be to review the participant report listing we provide against their current vested balance to determine which participants you could initiate cash-outs.
2. Ensure All Required Minimum Distributions (RMDs) Are Processed
Review if RMDs have been processed or will be processed before the end of the year. The chart below can be used to help you identify which participants are required to take an RMD and by when it must be processed.
| Participant Age & Timing | Participant Employment & Ownership Status | RMD Requirement |
| Participants over age 72 (70 ½ if you reach 70 ½ on or before December 31, 2019) | Terminated OR Own more than 5% of the company (including ownership through attribution) |
RMD is Required by December 31 |
| Participants over age 72 (70 ½ if you reach 70 ½ on or before December 31, 2019) | Actively employed with your company AND Do not own more than 5% of the company (including ownership through attribution) |
RMD is NOT Required (unless the Participant elected to begin receiving RMDs in a prior plan year) |
| Participants turning age 72 this year | Terminated OR Own more than 5% of the company (including ownership through attribution) |
RMD is Required; however, the first withdrawal may be deferred until April 1st of next year (one‐time election), but still must take an additional withdrawal for next year by December 31. |
3. Distribute The Summary Annual Report (SAR)
The Summary Annual Report (SAR) outlines in narrative form the financial information in the plan’s Annual Report (the Form 5500), and must be furnished annually to all participants. This includes active employees eligible to participate in the plan even if they don't have a vested account balance as well as terminated employees who still have a vested account balance. You may distribute in paper format or electronically. Timing of the notice is dependent upon when you filed the return pursuant to 29 CFR 2520.104b-10. In short, 9 months after the plan year ends or if on extension an additional 2 months from the extended filing deadline (9/30 and 12/15, respectively for calendar year end plans).
4. Verify Your Fidelity (ERISA) Bond Amount Is Sufficient
Each qualified plan must be a named insured under a fidelity bond from an approved surety covering plan officials and that protects the plan from losses due to fraud or dishonesty. ERISA requires a bond of at least the greater of 10% of plan assets or $10,000 to a maximum of $500,000 for qualified plans that do not contain employer securities. Bonding information is reported on the Form 5500 each year so make sure you are adequately covered.
For more information on the fidelity bonding requirements, see Field Assistance Bulletin 2008-04.
5. Plan Your Annual Review
Now is a great time to start planning for your Annual Review with your team and advisors. Your Annual Review combines many different aspects of your retirement plan into one concise meeting. In an Annual Review you should consider discussing, at the very least, the following topics:
- Plan Participation (overall rate of engagement with the plan compared to your eligible employee base)
- Plan Features & Specifications (features available to participants in your plan)
- Investment Policy Statement, Selections, and Education (this is where your Financial Advisor will be invaluable)
- Service Providers (like record-keepers) and the Services received.
We're happy to coordinate and participant in these Annual Reviews.
Click the Plan Review Request button above to contact us about coordinating you Annual Plan Review.
6. Review Your Uniglobal Reports
Uniglobal provides plan related reports to you throughout the year. Be sure to review these reports and contact your consultant with any questions. Inside our reports you'll find step-by-step instructions for any action items, such as: what participant notices need to be distributed, available forfeitures at year-end, and helpful tips and suggestions, just to name a few.
7. Year-End Calendar for 12/31 Plans
Important October - December Deadlines
| October 15 | Final filing deadline for Form 5500/5500-SF on extension |
| November 15 | Uniglobal release date for client Annual Notices |
| December 1 | DOL "Safe Harbor" deadline for distribution of certain Annual Notices |
| December 15 | Under extension, last day to provide the Summary Annual Report to plan participants |
| December 31 | Last day to issue RMDs |
As always, the team at Uniglobal is here to support you and your plan. If you have questions about year-end action items or best practices contact us!