ha ha ha. plan now. the 2016 forms aren't due until 11/15/2017

[Tom Poje]

who dreams up these silly things?

http://blogs.haynesboone.com/index.php/2015/08/firm/benefits/recent-legislation-extends-form-5500-filing-deadline-for-tax-years-beginning-in-2016/

Recent Legislation Extends Form 5500 Filing Deadline for Tax Years Beginning in 2016

Posted on August 13, 2015 by Haynes and Boone Benefits Group in Practical Benefits Lawyer

The recently enacted Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (the Act) extends the filing deadline for certain Form 5500 filers for plan years beginning after December 31, 2015. Specifically, for plan sponsors who have obtained an extension to file the Form 5500, the Act increases the extension from 2½ months to 3½ months from the initial deadline. Accordingly, for 2016, a plan sponsors deadline for filing the Form 5500 for a calendar year plan, assuming the plan sponsor obtained an extension, would be November 15, 2017 (rather than October 15, 2017). At this point, it is unclear whether a similar extension will apply to direct filing entities, such as master trusts, and to the deadline for filing the Form 8955-SSA. However, the extension has the effect of extending the deadline by which Summary Annual Reports (SARs) must be provided, since SARs must be provided within two months of the extended deadline for filing the Form 5500.

[My 2 cents]

Think how much easier things will be in 2017!

[ESOP Guy]

Great it will just give my clients a reason to wait another month to send me their data.

[My 2 cents]

Great it will just give my clients a reason to wait another month to send me their data.

If you think that's bad, what about the other discussion thread, where the plan sponsor is worrying NOW about whether a 12/31/16 deadline will really be extended to the next following business day! Now there's world-class procrastination!

[Lois Baker]

And then there's this:

The new rules contain an unusual exception: the revised tax return deadlines do not apply to C corporations with fiscal years ending on June 30 until taxable years beginning after December 31, 2025 (however, the revised Form 5500 extension deadline does apply effective in 2016 to plans and corporations with June 30 year ends).

http://www.relius.net/News/TechnicalUpdates.aspx?T=P&1=1&ID=1072

(via http://benefitslink.com/newsletters/2015/2015_09_16_welfare.html)

[Tom Poje]

I think I will appreciate the side effect even more, the very valuable popular and well read, oft referred to SAR gets extended as well.

[Peter Gulia]

Does this law change mean that a participant might get her December 31, 2017 account statement (in early January 2018 [see 17 C.F.R. 240.10b-10(b)(2)] before she gets her 2016 summary annual report (by January 15, 2018)?

[My 2 cents]

Does this law change mean that a participant might get her December 31, 2017 account statement (in early January 2018 [see 17 C.F.R. 240.10b-10(b)(2)] before she gets her 2016 summary annual report (by January 15, 2018)?

I don't think the law change affects other deadlines. Which means that your scenario could happen.

Who actually reads the SARs anyway? For a DB plan, how much attention is paid to the Annual Funding Notices?

And don't get me started about all those "privacy notices"! Too bad the government cannot effectively require identity thieves and hackers to provide privacy notices. Now that would be useful!

[Peter Gulia]

Perhaps there's also room for a mailing efficiency. A plan's administrator could ask its recordkeeper to enclose the 2016 summary annual report in the same envelope that mails the 2017Q4 account statement.

[GBurns]

Doing them together might leave the door open if a proof of mailing issue arises. It is always better to have separate mailings for each item.

[Peter Gulia]

But what if a retirement plan has 35,000 participants and the incremental mailing would result in incremental expenses of $25,000 charged against the plan's assets?

If, as My 2 Cents suggests, a fiduciary might find that few participants read the information, shouldn't such a fiduciary at least consider ways to reduce expenses that lower participants' accounts?

[GBurns]

That few participants read what is sent to them should not be a concern for a fiduciary, when regulatory compliance is the issue. But, as you point out reducing expenses should. Many decisions place fiduciaries between a rock and a hard place.

[GBurns]

Isn't it likely that there would be a timing conflict if the SAR is mailed with the Q4 Account statement?

It seems that the SAR must be provided "Automatically to participants and pension plan beneficiaries receiving benefits within 9 months after end of plan year, or 2 months after due date for filing Form 5500 (with approved extension). This might not fit with the timing of the Q4 Account Statement, especially if participant directed accounts.

[Peter Gulia]

Coordinating the deliveries might mean sending the summary annual report about a week sooner than would be required under the SAR rule alone.

If a calendar-year plan's Form 5500 report is filed on November 15, the summary annual report becomes due on January 15.

But a plan's administrator and recordkeeper might do the work so the summary annual report can be sent with the Q4 account statements in the first five business days of January.

[TPApril]

Now that the 5500 extended extension is not in effect, is there still an extension on corporate tax returns, and by default corporate contribution deadlines?