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Posted

The Instructions to Form 5500 state that an amended return should be filed to correct errors or omissions. In informal guidance or best practice, is there a materiality standard -- i.e., if the error or omission is immaterial, an amended return is not required? I realize this would introduce all sorts of subjectivity, but also hard to believe that DOL would want amended returns for inconsequential errors.

Posted

IMHO, this is completely in the judgment of the Plan Administrator. Realistically, this will mostly be the judgment of the TPA/Form preparer, because the Plan Administrator is likely to follow the recommendation of the preparer. Some preparers won't even bring a "trivial" error to the attention of the Administrator. And everyone will have their own standards.

For example, if I did a filing for a Welfare plan, and the participant count on one of the Schedule A's was filed as 778, and when preparing the next year's forms, I find it should have been 779, will I prepare an amended filing? He** No!!

On the other hand, if the "Plan Characteristics" codes were incorrect, I'd file an amended return.

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