Form 5500 Intranet Posting

[AndyH]

How are practicioners communicating and interpreting the new PPA requirement that plan sponsors post "actuarial information" from Form 5500 on company intranet sites?

There is very little guidance.

What due date are firms communicating? Are you telling your clients to include Schedule SB attachments? Anybody defining what an intranet is for this purpose?

What are the big firms communicating?

[Andy the Actuary]

Draft of what was sent to certain clients:

"This email applies to sponsors of defined benefit plans if your organization presently maintains or is considering maintaining an Intranet webstite. An Intranet website for this purpose is an internal website for sharing information among your employees but not with the public.

The Pension Protection Act of 2006 (PPA) now requires that certain information from your defined benefit plan 5500 must be posted on an organization's Intranet website. The posting requirement does not appear to apply to other plans such as a 401(k) or health and welfare plan.

While no posting reguations have been issued, a good-faith effort would be to scan and post the IRS Form 5500 (pages 1, 2, 3) with the Schedule SB (without attachments). Thus, you would not post Schedules A, C, D, G, H, I, R, and SSA. Note, that the information required to be posted is public record and so is otherwise available to employees (and the public!) anyway.

At this time, there is no guidance as to how soon the information should be posted. But, as a rule of thumb, if you have filed the 5500, it's time to post. PPA does not require you to notify your employees that information has been posted. Also, there is no requirement to notify and allow former employees and retirees to enter your Intranet website to view the posted information. "

[AndyH]

Thank you.

Any others willing to discuss their views or communications on this, or communications they have seen?

[Guest webuck]

DoL isn't showing any pages from the Form 5500 -just the Schedule SB or MB w/o attachments- so it would appear unnecessary on intranet (not sure WHY it would even be thought of, as PPA mentioned actuarial informatio only.). They did include the EA signature section including phone #, which could result in calls from employees. What is EA supposed to say? I propose eliminating that section from the SB entirely on intranet version, or somehow masking the contact information. Any thoughts???

[david rigby]

Elevating this. Any additional thoughts?

Mask the EA signature and phone number? Alternative: include "signed" instead of the actual signature.

Did anyone get any comments at the EA (or other) meeting?

[TPApril]

I'm curious how this is being handled today?