Navigating retirement plan rollovers has always required rigorous documentation and an up-to-date understanding of regulatory trends. As we enter 2025, recent changes to Form 5500 reporting bring a new level of detail and responsibility for those of us who facilitate rollover analyses and strive to maintain flawless compliance with rules like PTE 2020-02. At Simple Advisor Tools, we're deeply invested in what these changes mean for independent advisors, compliance teams, and everyone committed to best-interest standards.

Understanding the 2025 Form 5500 Changes: What's New and Why It Matters

New multiemployer plan characteristic codes (1J, 1K, 1L) for pinpointing why plans terminate—mass withdrawal, amendments, or insolvency—boosting transparency about plan status.
Code 1G for variable annuity formulas helps identify plans with complex payout calculations, impacting how we approach benefit comparisons.
Clarification of code 1H now exclusively marks terminated single-employer plans covered by PBGC, making clear distinctions to guide how we treat insurance protections and participant communications.
Electronic filing for extensions via Form 5558 provides more timely access to crucial plan data.
PBGC coverage cessation reasons are now more granular, offering extra context for rollover evaluations.

Each of these changes enhances the granularity and reliability of plan data. For us, accurate details mean less guesswork and stronger rollover recommendations, grounded directly in government-filed records—not assumptions or templates.

Impact on Rollover Analysis Compliance

More Precise Fee and Service Comparisons

Accessing richer, cleaner Form 5500 data isn't just a perk—it's now essential. Comprehensive plan characteristic codes let us quickly identify atypical terminations or unusual structures that can have a real impact on participant options. For example, distinguishing a mass withdrawal (code 1J) from a standard amendment (1K) allows our documentation to accurately outline why a participant's rollover is appropriate, especially when aligning with PTE 2020-02 requirements for objective and client-specific analysis.

Strengthening Audit Trails

With the clarified 1H code and new codes like 1G, our audit trails become not only easier to create but also much more defensible. Each time we cite specific Form 5500 plan data in generated rollover analysis PDFs, we lay a clear breadcrumb trail. This enables compliance officers or regulators to quickly verify that recommendations are anchored in bona fide, up-to-date filings. That's a strong position to be in should our advice be questioned.

Penalty Structures Raise the Stakes for Everyone

The increased financial and criminal penalties now associated with incomplete or inaccurate Form 5500 filings ($2,670 per day for non-compliance, among other strict figures) also indirectly validate the data we use. Plan administrators simply cannot take reporting lightly, which gives us more confidence in the numbers and facts on which we base our compliance documentation. Our reports clearly state that our analysis relies on data provided under intense regulatory scrutiny, solidifying our credibility in any audit situation.

Aligning PTE 2020-02 Documentation with Form 5500 Timing

Timing plays a bigger role this year. Form 5500 filings for calendar year plans are not due until July 31 of the following year and can be extended further. This means that, depending on the timing of a rollover, we might only have finalized plan data from the previous year. Clear documentation in our reports about the effective date of the data used not only informs clients but also demonstrates a good faith effort in using the best available disclosures. When the freshest numbers aren't available, noting that constraint is vital for defensibility.

Our Approach: Adapting Your Rollover Workflows

Step 1: Leverage the New Codes in Each Analysis

We make it a practice to review every new and revised Form 5500 code relevant to a client's situation. If a plan is flagged with 1G, we take extra steps to analyze variable annuity benefit formulas. If a plan is tagged with 1J, 1K, or 1L, we investigate the circumstances around the plan closure and fully document them in the report.

Step 2: Clearly State Data Sources and Currency

Transparency matters. Each analysis includes a statement like:

"Current plan data sourced from the 2024 Form 5500, filed June 2025. This is the most recent data available as of the analysis date."

This simple note provides meaningful protection against questions of currency and thoroughness by regulators.

Step 3: Analyze PBGC Coverage in Context

Whenever code 1H appears, we document PBGC protections in plain language. This aspect of the plan can dramatically change participants' risk assessments and options. By referencing the specific plan codes, our clients and regulators alike can see exactly how we arrived at our conclusions, reducing ambiguity and strengthening our advice.

Step 4: Highlight Verified Data Use

We underline our reliance on government-filed, penalty-enforced plan disclosures in every analysis:

"Fee data and service comparisons in this analysis are drawn from Form 5500 filings, submitted under penalty of perjury by plan administrators."

Step 5: Account for Stricter Participant Reporting

With updated electronic filing standards for Form 8955-SSA, participant status records are more likely to be accurate and accessible. This allows us to report on participant eligibility and termination status with even greater confidence. When analyzing rollovers for separated employees, we cite official filings, not assumptions or unsubstantiated HR records.

Example: How More Granular Data Improves Compliance

Suppose a 58-year-old client is considering a rollover from a defined benefit pension. Instead of a generic statement about plan type, we now reference:

Variable annuity code 1G, documenting the methodology for lump-sum calculation
PBGC protection via code 1H, noting the security this provides relative to a rollover
The exact filing date and year of the Form 5500 used in the analysis

Our best interest analysis spells out how these codes factor into comparing in-plan annuity benefits with potential IRA rollovers and helps the client understand the trade-offs. Every fact can be traced directly back to official filings—no shortcuts or assumptions.

Key Takeaways for Advisors and Compliance Teams

Incorporate the new codes: Make it a standard part of every analysis to check for 1G, 1J, 1K, 1L, and revised 1H codes.
Document exactly which Form 5500 year and filing date you use. Be explicit about data vintage, especially if current-year filings are not yet available.
Reference PBGC protection whenever relevant. This is crucial for terminated single-employer plans.
Include statements about data authority and penalty-driven accuracy to bolster your compliance story.
Leverage stricter participant data standards. Show that participant termination and eligibility is documented via Form 8955-SSA, supporting rollover eligibility.

Why Automation Makes Adapting to Change Manageable

While these updates offer new opportunities for robust compliance, they also demand more time and attention to detail—unless you automate. With integrated Form 5500 database tools like ours, you can instantly pull current plan data, flag new codes, and generate audit-ready, PTE 2020-02-compliant reports in minutes (not hours). This approach removes manual error, keeps your workflows aligned with regulatory expectations, and helps your team focus on serving clients rather than double-checking filings.

If you want to see how effortless it can be to adapt to these Form 5500 changes—and strengthen your compliance program in the process—we invite you to explore our audit-ready, DOL-compliant software for yourself. You can start a risk-free 14-day trial, where accuracy, transparency, and compliance are always our top priority.

How Recent Changes to Form 5500 Reporting Impact Rollover Analysis Compliance