Why did I receive an EPCU Compliance Check Letter?
We identified a population where the pension feature code(s) were missing, inconsistent or incomplete on Line 8a of the Form 5500, line 9a of the Form 5500-SF, and Form 5500-EZ line 8 for plan years ending in 2016 and later. We will correspond with the sponsors of the identified plans and request that the sponsors tell us which pension feature codes apply to their plans by annotating the appropriate codes on a list included with our correspondence. The letter will inform plan sponsors how to amend their returns to include pension feature codes. Your return may also be missing other items such as the business code and the total participant count. You should review your entire return for accuracy and other omitted items that should be addressed and corrected.
What is the EPCU attempting to determine?
Our primary goal is to correct missing and incomplete items on a return, like the pension feature codes, so that we have accurate return information. Additional goals are to identify the underlying causes for missing items and to make recommendations to improve our forms, instructions, and systems.
What actions do I need to take?
Review your Form 5500, 5500-SF or 5500-EZ, select the correct codes for your plan, and respond to us as requested. You will need to file an amended return with complete information. Our letter contains brief filing information and sources of additional information you may need. You should file your amended return with the Department of Labor (Forms 5500 or 5500-SF) or the IRS Service Center (Form 5500-EZ).
If You Have Questions
Please feel free to contact the person listed in the cover letter with questions about this project and how it relates to your situation.
A review of Form 5500 series returns showed that there are return filings for plans missing the pension feature codes, business codes, and total participant counts. Missing or incorrect codes create errors in our systems and lead to a gap in coverage of the designated plan segments.
The EPCU will be mailing the contact letter and attachment to a select group of plan sponsors. A closing letter will be issued to the plan sponsor upon completion of our review.