The new Form 5500 reporting and audit requirement represents sweeping changes to the administration of 403(b) plans for not-for-profit organizations including government, health care, religious, and higher education entities, as well as certain tax-exempt associations. The amount of technical expertise, analysis, and documentation necessary to satisfy these requirements is significant.
Despite the Department of Labor’s July 21 announcement that “transition relief” will be provided to plan administrators, organizations need to comply with the new regulations and show a “good faith” effort in doing so for the 2009 plan year.
Although the earliest due date for filing Form 5500 is July 31, 2010 for those plans with a calendar year end of December 31, 2009, now is the time to prepare.
Your plan’s independent auditor will need to know the answers to dozens of questions about the administration of your plan; this may be particularly challenging as many of these areas may not have been previously monitored or documented. Some of the issues that may be covered include plan reporting and governance, third-party service providers and controls, protection against fraud and the identification of “irregularities,” and virtually any other aspect of plan administration that could affect the plan’s operation and compliance with regulations.
J.H. Cohn understands the challenges that not-for-profit organizations face in complying with the new 403 (b) regulations. Our employee benefit plan professionals have the experience in employee benefit plan auditing, reporting, and compliance consulting to assist tax-exempt organizations in meeting their fiduciary requirements. Our employee benefit plan practice provides these services to over 450 plans.
Compliance with the new Form 5500 filing and audit regulations may seem daunting, but J.H. Cohn can help clarify the issues and help you prepare. Whatever you can accomplish now, ahead of the deadlines, will help you comply timely and successfully.