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IRS 2009 Form 8955-SSA--Getting a Plan in Place
August 2, 2011

As reported in the June 30, 2011, issue of Lindquist Solutions, the Internal Revenue Service (IRS) has released 2009 Form 8955-SSA, Annual Registration Statement Identifying Separated Participants with Deferred Vested Benefits. Form 8955-SSA is the successor to Schedule SSA (Form 5500). The former Schedule SSA, which contained participants' Social Security Numbers, was eliminated in 2009 to facilitate electronic filing of the publicly available Form 5500.

Now that the IRS has released the new form for 2009, reportable participants for 2009 and 2010 can be combined and reported on the 2009 Form 8955-SSA to satisfy the reporting requirements for both years. Alternatively, separate filings for 2009 and 2010 (using the 2009 Form 8955-SSA) will also satisfy the reporting requirements. Once the 2010 Form 8955-SSA becomes available, the 2010 Form 8955-SSA should be used to satisfy the reporting requirements for 2010 (if not already reported on the 2009 form).

Developing an Action Plan

It is important to develop an action plan to ensure timely filing of the form.

The Board of Trustees / Plan management should decide, as soon as possible, which service provider will prepare Form 8955-SSA for 2009, 2010 and going forward. The third-party administrator or recordkeeper usually maintains the SSA data; however, the Plan's accounting firm may have the capability to prepare the form. For example, Lindquist LLP has subscribed to professional software that allows our firm to import data in electronic format to generate the new Form 8955-SSA.

Once a service provider has been selected, all parties involved should establish a project timeline. The special filing due date for the 2009 and 2010 Form 8955-SSA is the later of:

  • January 17, 2012, or
  • The due date that applies for filing the 2010 Form 5500, including the 2½-month extension that is available to extend the normal deadline by completing IRS Form 5558. One extension on Form 5558 can be completed to extend both the 2010 Form 5500 and the 2010 Form 8955-SSA.
If an extension for the 2010 Form 8955-SSA is necessary, an authorized representative will need to complete and file the extension on Form 5558. The authorized representative should also be responsible for tracking the filing of Form 8955-SSA and extensions (as applicable) going forward.

Filing Method Update

Previously, the IRS indicated that electronic filing of the form would be an option; however, the electronic filing method is still pending with the IRS and is expected to be available next year at the earliest. At this time, Form 8955-SSA must be filed by paper.

What Changed?

The IRS made two notable changes to the form:

  • Line 8 is new - Did the plan administrator provide an individual statement to each participant required to receive a statement?
  • Column (c) for Line 9 includes a field to add a checkmark if the information reported for a participant is based on incomplete records.

Contact Us

Lindquist LLP is prepared to assist plans with filing of Form 8955-SSA. Please contact Partner Michelle McCann at (925) 277-9100 or mmccann@lindquistcpa.com with questions.

Michelle L. McCann, CPA, is a partner in Lindquist LLP's San Ramon office.  She is primarily responsible for overseeing quality control for preparation of exempt organization and employee benefit plan returns, including Forms 5500, 990, LM-2 and 199.  Michelle also provides QuickBooks training and support for the firm's clients.

 

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