As discussed in a prior blog post, the CARES Act allows defined benefit plan sponsors to delay any minimum required contribution for 2020 until January 1, 2021. However, the CARES Act did not delay the filing deadline for a plan’s Form 5500. This means that if a plan sponsor delays the contribution, as allowed by the CARES Act, to a date that falls after the applicable Form 5500 filing deadline, the plan sponsor will need to file an amended Form 5500.
Recent IRS guidance explains the requirement. A plan sponsor must make sure it designates to which plan year any contributions made after the Form 5500 filing date applies. If the contributions are for the prior plan year (the plan year ending in 2019), an amended Form 5500 that includes an amended Schedule SB would need to be filed in order to reflect those contributions. That is because a plan’s actuary may not report contributions on Schedule SB of the Form 5500 that will be made after the actuary signs the Schedule SB.
The delay to make contributions is welcome relief for many plan sponsors but do not get tripped up by the failure to file an amended Form 5500. If you have any questions about the CARES Act or any other employee benefits issue, please contact any of the Graydon employee benefits team.
