The Schedule SSA of Form 5500 has been eliminated beginning with returns for the 2009 plan year and has been replaced with Form 8955-SSA, Annual Registration Statement Identifying Separated Participants with Deferred Vested Benefits. The information reported on the new form will be similar to the information previously required for Schedule SSA. Plan administrators will be required to file this new form with the IRS; however, it will not be electronically filed with Form 5500 through the EFAST2 filing system.
Plan administrators are not required to file the Form 8955-SSA for the 2009 plan year and subsequent years until guidance is issued by the IRS. The IRS anticipates the guidance will establish a special due date, expected to occur in 2011, for the 2009 Form 8955-SSA. After Form 8955-SSA and related instructions are available for filing, plan administrators should expect to have a reasonable amount of time to complete and file the form by the special due date.
The special due date for Form 8955-SSA will not affect the timeframe for filing the applicable Form 5500 or Form 5500-SF for the 2009 plan year through EFAST2.
By Bob Cann, CPA, Partner, Director of Compliance Services, rcann@legacycpas.com