Client Alert

The Swan Song of Schedule SSA to Form 5500

March 09, 2011

Stephen Harris & Eric Keller

Plan administrators of 401(k), pension and other retirement plans subject to ERISA section 203s vesting requirements have long been required to file Schedule SSA (identifying separated participants having deferred vested benefits) with their Form 5500s in order to satisfy their reporting obligations under Internal Revenue Code (Code) section 6057(a). In particular, Schedule SSA required plan administrators to report if an employee separated from employment with vested benefits, no part of which were paid during that year, transferred into the plan during the plan year with vested benefits under another plan that become payable under the plan (e.g., a plan merger), no part of which were paid during that year, or previously was reported on a Schedule SSA, but is no longer entitled to those deferred vested benefits. The Department of Labor recently amended Form 5500 to eliminate the requirement to include Schedule SSA with the 5500 for plan years commencing after December 31, 2008.

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