As the October 15 Form 5500 filing deadline quickly approaches, there are some important items you should address sooner rather than later:
- Contact your service provider. If your service provider agreement states that non-discrimination testing will be performed ensure that it has been completed and any corrective actions have been executed. Year-end plan reporting prepared by the service provider should be reviewed by the plan sponsor for any discrepancies or significant changes in the accounts.
- Contact your auditor and Form 5500 preparer (if separate from your service provider). Make sure your auditors and Form 5500 preparers are on time with their procedures to meet the filing deadline. Often, auditors will need to work with the Form 5500 preparer to reconcile the amounts reported on the Form 5500 to the amounts reported in the financial statements. Finally, confirm the timing of the auditors’ presentation of their results to the Plan’s oversight committee.
- Schedule a meeting of the Plan’s oversight committee. The communication of the audit results is an important discussion between the plan auditors and the oversight committee. While the committee should be meeting regularly throughout the year, this is also an ideal time to revisit plan provisions and confirm that the Plan is operating as intended. At the conclusion of the audit, if any significant deficiencies or material weaknesses are identified in the audit, the auditor will communicate these to the committee. Remediation plans can also be determined with the committee at this time. Your auditors should also provide you with potential process improvements that you can review and use to re-evaluate processes and controls.
The fines for missing this filing deadline can be significant. Follow the steps noted above to verify that your company is on track to avoid any penalties.