We reported in our last issue that one of the changes made by the Department of Labor when mandating electronic filing of Form 5500, Annual Return/Report of Employee Benefit Plan, was the removal of Schedule SSA from the Form 5500. Form 8955-SSA, Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits, replaced the Schedule SSA and is filed with the Internal Revenue Service as a stand-alone form for plan years beginning on or after January 1, 2009.
As mentioned, the new Form 8955-SSA will still follow the due date of the Form 5500, which is the last day of the seventh month following the plan year end with an extension available for two and one-half months. The IRS had announced that the due date for filing the Form 8955-SSA for the 2009 and the 2010 plan years was the later of either the due date that generally applies for filing the Form 8955-SSA for the 2010 plan year or August 1, 2011. The August 1, 2011 deadline for filing 2009 Form 8955-SSA could be extended to October 15, 2011 if a Form 5558, Application for Extension of Time To File Certain Employee Plan Returns, was timely filed. More recently, in June 2011 the IRS announced the filing deadline for 2009 and 2010 forms was extended from August 1, 2011 to January 17, 2012. The individual statement that must be furnished to the separated participant should be furnished no later than the due date for filing the Form 8955-SSA.
The IRS will allow the preparation of one Form 8955-SSA covering both 2009 and 2010 reportable employees. In that case, the 2010 reportable employees are treated as reported in 2009. A plan that reports on a calendar year basis and combines information for the 2009 and 2010 plan years should enter January 1, 2009 as the beginning date and December 31, 2009 as the ending date.
This new due date is important for pension plans. Should your plan need guidance on the form, please make sure to contact your actuary or third-party administrator. This is a form that may not necessarily be prepared by your plan's CPA firm.