Advance Copies of 2011 Form 5500 Released


The U.S. Department of Labor's Employee Benefits Security Administration, the Internal Revenue Service and the Pension Benefit Guaranty Corp. released advance informational copies of the 2011 Form 5500 annual return/report and related instructions on December 20, 2011.

Employers that sponsor pension and welfare benefit plans required to electronically file an annual return/report regarding their financial conditions, investments and operations each year generally satisfy that requirement by filing the Form 5500 or Form 5500-SF and any required schedules and attachments.

Modifications to the Form 5500 and Form 5500-SF for plan year 2011 are described under "Changes to Note" in the 2011 instructions, including:
  • The actuarial schedules (Schedule MB and Schedules SB) have been updated to reflect provisions of the Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010.
  • The instructions are updated to include the information in the EFAST2 Frequently Asked Questions explaining when a service provider who manages the filing process for the plan can get EFAST2 signing credentials and submit the electronic Form 5500 for the plan.
  • The Schedule C instructions are updated to advise that for a multiemployer defined benefit plan or other multiple-employer plan where the plan sponsor is the joint board of trustees for the plan, payments by contributing employers, directly or through an employer association, or by participating employee organizations, should be treated the same as payments by a plan sponsor.
  • The Schedule I and Form 5500-SF instructions are updated to advise that for plans with fewer than 100 participants at the beginning of the plan year, any amount deposited with or repaid to such plan not later than the seventh business day following the day on which such amount is received by the employer or on which such amount would otherwise have been payable to the participant in cash, shall be deemed to be contributed or repaid to such plan on the earliest date on which such contributions or participant loan repayments can reasonably be segregated from the employer’s general assets.
Informational copies of plan year 2011 forms, schedules and instructions are available online at These advance copies are for informational purposes only and cannot be used to file a 2011 Form 5500 annual return/report. Filers should monitor the EFAST website for the availability of the official electronic versions for filing using EFAST-approved software or directly through the EFAST website.


Hedley Lawson, Contributing Editor
Managing Partner
Aligned Growth Partners, LLC