5500 Data Required for 401(k) and Pension Plans - are HCE and Key EEs lists requested

Would you agree that HCE and Key Employee status do not factor into Form 5500 filing for welfare plans, even 401(k) and other Pension Plans?  Thanks, SAD

I don't think so.  Is someone asking for a list of HCE & Key EEs?

I'm not aware of needing HCE or Key EE data to complete Form 5500.  I seem to recall there was a time period is recent history that the IRS tried to add some questions to the Schedule R that dealt with nondiscrimination testing that would have required some HCE data at least but it became optional and then dropped in subsequent drafts of the Form.  

HCE and Key data would be required to perform certain non-discrimination tests but not necessarily the 5500 or related schedules itself.

The only way I could see them tied into the 5500 is that they are excluded from the plan for some reason and are not int he participant count because of it.

2 hours ago, Lou S. said:

I'm not aware of needing HCE or Key EE data to complete Form 5500.  I seem to recall there was a time period is recent history that the IRS tried to add some questions to the Schedule R that dealt with nondiscrimination testing that would have required some HCE data at least but it became optional and then dropped in subsequent drafts of the Form.  

These questions are coming back starting in 2022, if the proposal that was released a couple of days ago is finalized. It will be on the Schedule R, 5500-SF, and 5500-EZ.

Thanks to both of you,

BG5150 - EE said clients were gettting asked by 5500 vendor or CPA based on incomes as the compliance form listed income requirements for Non-Disrimination Testing at  2016 levels, which I updated to 2020-2021 recently with a new company.  I mentioned if was not needed for Form 5500, but was of NDT.

Lou S. and C.B. Zeller:  Thanks for the reminder (2022) proposed changes, as the Drug Pricing proposal did not pass out of committe on 9/15/21 per reports today.  I am sure many changes are likely with many of the provisions proposed.