September 2016


DOL Extends Form 5500 Comment Deadline

Last week, the Department of Labor (DOL) announced  a two-month extension of the comment period on the Form 5500 Modernization Proposals, which applies to dental plans (see Hogan Lovells applicability memo). The new deadline for comments is Monday, Dec.5.

A subgroup of the Commission on Advocacy Policy (CAP) will continue to meet to review the proposed changes to Form 5500 and develop comments from the industry. Currently the subgroup is reviewing applicability and costs associated with the new reporting requirements included within Schedule J. Please continue to share your thoughts on the proposed rule’s applicability and impact to dental benefits NADP staff. (Future updates on this topic will be posted to the Advocacy Open Forum)

EBSA News Release: 09/20/2016


WASHINGTON – The U.S. Department of Labor has announced a two-month extension of the comment period on the Form 5500 Modernization Proposals. The department, the Internal Revenue Service and the Pension Benefit Guaranty Corporation published a Notice of Proposed Revision of Annual Information Return/Reports in the Federal Register on July 21, 2016. The department also published a separate, but related Notice of Proposed Rulemaking on the same day.

The forms revisions and regulatory amendments were proposed as part of a project to improve and modernize Form 5500 annual return/reports filed by employee benefit plans. The forms revisions and regulatory amendments generally are being coordinated with a recompete of the contract for the ERISA Filing Acceptance System II – the wholly electronic system, commonly known as EFAST2, that is operated by a private-sector contractor for the processing of Form 5500/5500-SF return/reports.

A range of stakeholder groups asked for an extension of time to submit comments given the scope and significance of the proposed forms revisions and regulatory amendments. The department, IRS and PBGC decided to extend the public comment period on the proposed forms revisions and regulatory amendments from the original Oct. 4, 2016, deadline to the new Dec. 5, 2016, deadline. The result will be a total of almost five months for interested persons to prepare and submit comments. This step is intended to facilitate robust and thoughtful public input on the proposals while respecting the need to keep the rulemaking aspects of the project moving forward and on pace with procurement and system development objectives to recompete the contract acquisition plan.

Notice of this extension will be published in an upcoming edition of the Federal Register. The Notice of Proposed Forms Revision and the Notice of Proposed Rulemaking is available at the Employee Benefits Security Administration’s website,



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