Understanding Form 5500 and Compliance Requirements

What is the Form 5500?

The Form 5500 is an annual report filed with the U.S. Department of Labor that provides financial, investment, and operational details about a 401(k) plan. It satisfies annual reporting requirements under ERISA and the Internal Revenue Code.

Betterment prepares the form for plans covered by the applicable service, but the plan sponsor is responsible for reviewing, signing, and completing the filing process.

Betterment does not prepare the Form 5500 for solo 401(k) accounts.

 

Where can I find my Form 5500?

The Form 5500 is not located in the Betterment Plan Sponsor Dashboard. Betterment makes the form available through FT William, the separate third-party portal used for Form 5500 access and signing.

 

Do I use my Betterment password to log in to FT William?

No. FT William uses separate login credentials from your Betterment Plan Sponsor Dashboard.

 

Who is responsible for signing the Form 5500?

An authorized representative of the plan administrator or plan sponsor, including the CEO, CFO, HR Director, or plan administrator. The company decides who signs the form.

 

Betterment prepares the Form 5500 and sends it to the signer named during annual compliance testing. The signer can be updated at any time if needed.

Some providers may say that they sign the Form 5500 for you, but the liability for proper submission will always fall with the plan sponsor.

 

How is the Form 5500 signed and submitted?

Once The Form 5500 is prepared, the designated signer will receive instructions to complete the filing process electronically through FTWilliam.

If you forgot your FT William password, go to the FT William login page and select “Forgot Password.” If you never received the invitation, cannot locate your username, or are unsure whether you are the designated signer, contact Plan Support so we can confirm the status and help with the next step.

 

I did not receive the email with my FT William login information. What should I do?

First, check your spam or junk folder for messages from Betterment or FT William. Also confirm that you are the person listed as the Form 5500 signer for the plan.

If you still cannot find the invitation, contact Plan Support. We can confirm whether the form is ready, verify the signer information, and coordinate a resend when appropriate.

 

What is the difference between the short form and long form 5500?

  • Form 5500-SF (Short Form): Used by plans with fewer than 100 participants at the beginning of the plan year and that meet specific eligibility requirements.
  • Form 5500 (Long Form): Required for plans with 100 or more participants, which must also submit additional schedules and may require an audit.

 

When is the Form 5500 due?

The Form 5500 is due by July 31, which is seven months after the end of the plan year. If necessary, Betterment will file an extension on your behalf to extend the deadline until mid-October.

 

How can I check whether Form 5500 was filed and accepted?

You can search the Department of Labor’s EFAST2 filing database by plan name, employer identification number (EIN), plan number, or acknowledgment ID:

Search Form 5500 filings on EFAST2

If you cannot find the filing or the information does not match your plan, contact Plan Support so we can help determine the next step.

 

Who is required to have a 401(k) audit?

A plan is required to undergo an independent audit if it has 100 or more participants with account balances at the beginning of the plan year. Participants include:

  • Employees actively contributing to the plan
  • Employees with an account balance, even if no longer contributing
  • Terminated employees who still have assets in the plan
  • Beneficiaries with a current balance

Prior to 2023, the participant count included all eligible employees, regardless of account balance. The updated methodology now counts only those with account balances.

What are the penalties for filing the Form 5500 late?

Both the DOL and IRS impose penalties for late filing:

  • DOL Penalty: Up to $2,739 per day with no maximum limit.
  • IRS Penalty: $250 per day, up to $150,000 total.

The plan sponsor (the company) is responsible for ensuring the Form 5500 is filed on time. Betterment assists in the process but cannot file the form on behalf of the company.

 

Does a terminated plan still need to file Form 5500?

A plan generally must file for each year in which it had assets, even if the plan has since terminated. If Betterment held the plan’s assets on 12/31 of the relevant plan year, Betterment is responsible for preparing that year’s Form 5500; future filings may be handled by the new recordkeeper or plan administrator.

Because filing responsibility depends on the plan’s history and year-end status, contact Plan Support for plan-specific questions.

 

Why did we receive an IRS letter about the Form 5500?

The IRS may send a letter regarding the Form 5500 even if it was submitted. The processing time varies, and the submission status can be confirmed through the DOL EFAST Search Tool.

 

Who files the Form 5500 if my company moved away from Betterment?

If Betterment held plan assets on December 31 of a given year, Betterment is responsible for preparing the Form 5500 for that year. Future filings will be handled by the new recordkeeper or the plan administrator.

 

What is the Summary Annual Report (SAR)?

The Summary Annual Report (SAR) is a summary of the Form 5500 that outlines:

  • The plan’s asset value
  • Plan expenses (including administrative expenses)
  • Other key financial details

The SAR must be provided to plan participants within nine months after the end of the plan year if filed by July 31st or two months after the extended deadline if filed by October 15th.

 

How do I access the SAR report?

The SAR report can be downloaded within the FTWilliam portal. It is the plan sponsor’s responsibility to distribute the SAR to employees. Betterment at Work cannot distribute it on the company’s behalf.

 

Who must receive the SAR report?

The SAR report must be distributed to:

  • Active employees, whether they contribute to the plan or not.
  • Beneficiaries receiving benefits
  • Terminated employees who had a balance during the plan year.

Employers must ensure timely distribution of the SAR report to comply with ERISA disclosure requirements.