Plan Sponsor Name not updated on Plan Document

[KP19]

The plan sponsor had a small name change from 'Inc' to 'LLC' as of 1/1/2024.  The ERISA plan document was not updated to reflect this during 2024, but will be updated at some point during 2025.  Should the 2024 Form 5500 filing for the plan year ending 12/31/24 follow the plan document or the legal company name?

[Bri]

I'd use the actual legal plan name as reflected on the document, and I'd also never worry about the IRS caring one way or the other unless the plan would also have much bigger fish to fry under an audit.  You can update the name change on the 5500 after it's actually been effected.

[KP19]

Thanks, this is helpful!

[Peter Gulia]

And when you turn to reporting one or both changes, Form 5500 part II line 4 and the Instructions for it (page 18) state details about how to report a change in the plan’s name or a change in the sponsor’s name.

The format recognizes that either of these names might have changed when the other has not.

https://www.dol.gov/sites/dolgov/files/ebsa/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500/2024-form-5500.pdf

https://www.dol.gov/sites/dolgov/files/ebsa/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500/2024-instructions.pdf