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5500-EZ and Schedule SB Timing


Dougsbpc

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For a one participant Defined Benefit Plan:

The 5500-EZ instructions indicate that the schedule SB should not be filed but instead it must be retained with plan records. The instructions also indicate that the enrolled actuary must deliver the certified schedule SB to the filer no later than the filing deadline.

It appears there is no requirement to actually wait for the schedule SB before filing. For example, if a client is on extension until 10/15/13 but files the 5500-EZ on 8/7/13, is that a problem if the SB is not signed until 10/14/13?

Thank.

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Are there extenuating circumstances why the SB cannot be prepared or delivered? Presumably, all 2012 contributions have been made by 8/7/2013?

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

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We are a plan administrator and have an outside actuary certify all the schedule SBs. Sometimes clients are quite eager to file right away. However, the actuary is often swamped between 8/1 and 10/15 (understandably). This because often many of the small clients fund late in the year. It seems like as long as the actuary delivers the certified SB by 10/15 (the filing deadline) per the 5500-EZ instructions, the SB would be considered retained with plan records.

In any event, really appreciate the responses on this issue that may not have a clear answer.

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  • 6 years later...

I was wondering the same thing, six years later.

Both 5500-SF and 5500-EZ indicate that the plan sponsor is signing under penalty of perjury that any actuarial schedule has been completed as well.  So I think signing the 5500 earlier than the SB would be legally problematic.

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