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ARTICLE · 20 APRIL 2011

Form 5500 Update: IRS Issues Guidance On Replacement To Schedule SSA

Venable LLP
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Until April 20, 2011, plan administrators can submit either the old Schedule SSA or the new Form 8955-SSA to report terminated participants who have deferred vested benefits, for any filings they are making for the 2009 or 2010 plan years.

United StatesEmployment and HR
Andrea O'Brien
Andrea O'Brien
Lisa Tavares
Lisa Tavares
Jessica Kuester
Jessica Kuester

Executive Summary

Until April 20, 2011, plan administrators can submit either the old Schedule SSA or the new Form 8955-SSA to report terminated participants who have deferred vested benefits, for any filings they are making for the 2009 or 2010 plan years.  However, after April 20, 2011, plan administrators must use the new Form 8955-SSA.  Therefore, plan administrators should take steps now with their recordkeepers to make sure that this new filing requirement will be satisfied.

The Schedule SSA, which was previously filed with the Department of Labor along with a Plan's Form 5500 in order to report participants who terminated employment with deferred vested benefits, was eliminated for 2009 and later plan years when electronic filing was implemented for Forms 5500.  Recently, the IRS released Announcement 2011-21, which provides that the Schedule SSA is being replaced with the new Form 8955-SSA that will be filed directly with the IRS.  The 8955-SSA

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