Check contribution timing, participant counts, fees and filing status before signing. Separate operational corrections from the annual report’s preparation.
July 21, 2025 · Financial Forte Staff
Historical article: prepared retrospectively using information available as of July 21, 2025.
The request to sign Form 5500 often arrives when the owner or CFO is already busy with other deadlines. It can be tempting to assume that a completed form means the plan's records have been fully reconciled and every operational issue has been resolved. The filing deserves a more deliberate review.
Use the annual report as a checkpoint for how the retirement plan actually operated. Confirm the participant counts, contribution records, fees, required attachments and unresolved exceptions before signing. The preparer provides important technical support, but the employer and plan administrator need to understand the information being reported.
Confirm the filing and deadline first
For a calendar-year plan reporting 2024 activity, the normal Form 5500 filing deadline is July 31, 2025. A timely Form 5558 can generally provide an extension of up to two and a half months, subject to the applicable rules. Different plan years and special situations can produce different dates.[1]
Ask which form and schedules apply to the arrangement. A standalone ERISA-covered 401(k), an owner-only plan, a defined benefit plan and a pooled arrangement do not necessarily have the same filing responsibilities. An extension of this annual report also does not automatically extend every other plan deadline.[1]
Confirm who will sign, who will transmit the filing and who will check its status afterward. A file prepared by the service provider is not proof of a successfully submitted report. Keep the final filing and confirmation with the plan's records, and assign someone to follow up if the status shows an error or processing has stopped.
Reconcile the operational numbers
Compare employee deferrals and loan repayments withheld through payroll with the amounts actually received by the plan. A total that agrees at year-end can still conceal late deposits during the year. For ERISA-covered plans, the general rule requires deposit as soon as contributions can reasonably be separated from employer assets. A plan with fewer than 100 participants at the beginning of the plan year can instead rely on the safe harbor for qualifying deposits made within seven business days after receipt by the employer or the date the amounts would otherwise have been payable to the employee in cash. Meeting that safe harbor satisfies this timing rule even if the employer could deposit sooner. The following month’s fifteenth business day is an outer limit for pension plans, not a routine deposit target.[2]
Consider a hypothetical employer whose payroll records show $240,000 of employee deferrals for 2024. The trust records show $238,500 received by year-end, with $1,500 received in early January. The team should identify the pay date, normal processing capability and actual deposit date associated with that amount. The difference may involve a year-end timing item, but it still needs a documented explanation and assessment.
Now suppose the employer's contribution calculation shows $40,000, while the administrator's draft workpapers show $39,000. The $40,000 expected amount less $39,000 in the draft creates a separate $1,000 difference that should be traced to compensation, eligibility, contribution timing or another supported explanation. Both reported amounts are below their comparison figures. The two differences add to $2,500 before any supported timing adjustments; netting one against the other to report $500 would conceal the direction and size of the discrepancies.
Ask the preparer how each item is reported under the applicable accounting and form instructions. If a correction is required, identify the method, amount, responsible party and completion date. A filing entry can disclose an issue without resolving the underlying problem.[1]
Verify counts and audit requirements using the right rule
The number of people on payroll is not always the count used to determine a defined contribution plan's small-plan or large-plan filing category. Under the 2024 instructions, an ongoing defined contribution plan generally uses the number of participants with account balances at the beginning of the year for this purpose. A first return uses the specified end-of-year count instead.[1]
Suppose the hypothetical employer has 160 workers, 120 people eligible for the plan and 95 participants with account balances at the beginning of the reporting year. Assuming this is an ongoing defined contribution plan, the relevant starting count for that classification is 95, not simply 160 or 120.
That does not by itself establish that every audit requirement is waived or that Form 5500-SF can be used. Other conditions apply. The 80–120 participant rule can also affect the filing category when a prior-year report was filed. Have the preparer document the rule used and the applicable audit or waiver analysis.[1]
Review terminated employees with balances and other participants who may have disappeared from the active payroll roster. A count based only on current employees can omit people whose accounts still matter for reporting and administration.
Read the fees and exceptions before approving the report
Compare reported expenses with provider invoices and account deductions. If an expense is paid directly by the employer, identify how it differs from a charge paid from plan assets. Review the applicable reporting requirements and avoid assuming that a zero in one field means the arrangement has no cost.
Fee reporting also supports the broader fiduciary review. For an ERISA-covered plan, evaluating reasonable fees and monitoring service providers remains important even when a preparer completes the annual report. A filing is a useful source of information; it is not a substitute for that process.[3]
Ask specifically about late contributions, participant loans, losses, prohibited transactions and unresolved data discrepancies. The proper treatment depends on the facts and current correction guidance. Do not carry an old correction method forward without confirming that it still applies.
The final review should leave the signer able to explain significant changes from the prior year and identify any open corrective work. After submission, verify the filing status and retain the accepted materials. A careful annual review can catch errors earlier, reduce repeated correction work and improve the reliability of the benefit employees depend on.
Related reading
Have more questions about Form 5500 review and retirement plan administration? Email Dave at dave@financialforte.com to discuss your questions and next steps.
The contact invitation is current; it does not imply this contact path existed on the historical reference date.
Educational information, not personalized investment, tax, legal or benefits advice. Examples use hypothetical assumptions. Verify current rules and your circumstances before acting.
Sources
- [1] DOL/IRS/PBGC 2024 Instructions for Form 5500 — Informational release November 25, 2024; electronic series January 1, 2025
- [2] DOL final rule on employee contribution deposits — 2010-01-13; rule effective 2010-01-14
- [3] Meeting Your Fiduciary Responsibilities — September 2021; SEC: How Fees and Expenses Affect Your Investment Portfolio — February 2014; SEC publication 164
