Tucked away in the provisions of The Co-Operative and Small Employer Charity Pension Flexibility Act, enacted in April 2014, was a revision to the Employee Retirement Income Security Act of 1974 (ERISA), which adds additional reporting requirements for multiple employer pension plans.
Specifically, ERISA as amended now mandates that the Annual Report (Form 5500) for multiple employer pension plans include a list of all participating employers in the plan and a “good faith” estimate of the percentage of total contributions made by each participating employer for the plan year. The revision is effective for plan years beginning after December 31, 2013. This means the 2014 Form 5500 will need to include this information.
The Department of Labor (DOL) issued an interim rule at the end of October to revise the Form 5500. Under this rule, the Form 5500 for a multiple employer pension plan will need to include a schedule listing each participating employer, the participating employer’s EIN, and the participating employer’s percent of total contribution.
This reporting revision will affect all plan administrators of multiple employer pension plans. Typically, these are professional employer organizations (PEOs) or certain entities that have been able to create multiple employer programs because the participating employers share some sort of employment nexus. Because the information listed above will be needed to complete the 2014 Form 5500, such administrators are advised to set up the appropriate administrative systems now to collect the information for the 2014 Form 5500 filing.