2019-06-05_SS_1545-2187 finalrKD

2019-06-05_SS_1545-2187 finalrKD.docx

Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits

OMB: 1545-2187

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SUPPORTING STATEMENT

Form 8955-SSA

Annual Registration Statement Identifying Separated

Participants With Deferred Vested Benefits

OMB Control Number 1545-2187


  1. CIRCUMSTANCES NECESSITATING COLLECTION OF INFORMATION

In 2007, the Department of Labor (DOL) published a final rule requiring plans subject to the annual reporting requirements of Title I of the Employee Retirement Income Security Act (ERISA) to electronically file the Form 5500, Annual Return/Report of Employee Benefit. In order to accommodate the DOL's mandate for electronic filing of the Form 5500 series, Schedule SSA has been eliminated.


For plan years beginning on or after January 2009, the Form 8955-SSA must be used to comply with the reporting requirement of IRC Section 6057(a). The IRS will no longer accept Schedule SSA (Form 5500) that is filed for a 2009 or later plan year. The general due date for filing Form 8955-SSA is the last day of the seventh month following the last day of that plan year.


  1. USE OF DATA


The information provided by plan sponsors on Form 8955-SSA will be transmitted to the Social Security Administration (SSA) who will provide it to separated participants when those participants file for social security benefits.


  1. USE OF IMPROVED INFORMATION TECHNOLOGY TO REDUCE BURDEN


An electronic filing system is available.


  1. EFFORTS TO IDENTIFY DUPLICATION


The information obtained through this collection is unique and is not already available or use or adaption from another source.


  1. METHODS TO MINIMIZE BURDEN ON SMALL BUSINESSES OR OTHER SMALL ENTITIES


There are no small entities affected by this collection because a Plan administrator of plans subject to the vesting standards of section 203 of ERISA must file Form 8955-SSA. For example, the plan administrator of a section 403(b) plan that is subject to the vesting standards of section 203 of ERISA must file a Form 8955-SSA for the plan's deferred vested participants.


  1. CONSEQUENCES OF LESS FREQUENT COLLECTION ON FEDERAL PROGRAMS OR POLICY ACTIVITIES


The information required is needed to verify compliance with the Internal Revenue Code Section 6057(a). A less frequent collection of taxes and tax information could adversely affect the government’s effectiveness and would reduce the oversight of the public in ensuring compliance with Internal Revenue Code and hinder the IRS from meeting its mission.



  1. SPECIAL CIRCUMSTANCES REQUIRING DATA COLLECTION TO BE INCONSISTENT WITH GUIDELINES IN 5 CFR 1320.5(d)(2)


There are no special circumstances requiring data collection to be inconsistent with Guidelines in 5 CFR 1320.5(d)(2).


  1. CONSULTATION WITH INDIVIDUALS OUTSIDE OF THE AGENCY ON AVAILABILITY OF DATA, FREQUENCY OF COLLECTION, CLARITY OF INSTRUCTIONS AND FORMS, AND DATA ELEMENTS


In response to the Federal Register notice dated April 12, 2019 (84 FR 15043), we received no comments during the comment period regarding these regulations.


  1. EXPLANATION OF DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS


No payment or gift has been provided to any respondents.


  1. ASSURANCE OF CONFIDENTIALITY OF RESPONSES


Generally, tax returns and tax return information are confidential as required by 26 U.S.C. 6103.


  1. JUSTIFICATION OF SENSITIVE QUESTIONS


A privacy impact assessment (PIA) has been conducted for information collected under this request as part of the “Business Master file (BMF)” and a Privacy Act System of Records notice (SORN) has been issued for these systems under IRS 22.062 – Electronic Filing Records; IRS 24.030 – Customer Account Data Engine (CADE) Individual Master File; IRS 24.046 - CADE Business Master File (BMF);IRS 34.037 - IRS Audit Trail and Security Records System. The Internal Revenue Service PIA’s can be found at http://www.irs.gov/uac/Privacy-Impact-Assessments-PIA.


Title 26 USC 6109 requires inclusion of identifying numbers in returns, statements, or other documents for securing proper identification of persons required to make such returns, statements, or documents and is the authority for social security numbers (SSNs) in IRS systems.


The Privacy Act statement for Form 8955-SSA can be found in the instructions.


  1. ESTIMATED BURDEN OF INFORMATION COLLECTION


Form 8955-SSA is used to comply with the reporting requirement of IRC Section 6057(a). Plan

administrators of plans subject to the vesting standards of section 203 of ERISA must file Form

8955-SSA. The agency estimates that there are 200,000 responses annually and that it takes .83

hours to complete for overall annual burden of 166,000 hours.


The information collection for NPRM (REG-117472-14) - Reporting and Notice Requirements for Deferred Vested Retirement Benefits under Section 6057 rule is covered under 1545-2187, however, does not add extra burden.

Form

Description

# Respondents

# Responses Per Respondent-

Approximate

Total Annual Responses

Hours Per Response

Total Burden

8955-SSA

Annual Registration Statement Identifying Separated

Participants With Deferred Vested Benefits

200,000

1

200,000

.83 hours

166,000

TOTAL


200,000


200,000


166,000



  1. ESTIMATED TOTAL ANNUAL COST BURDEN TO RESPONDENTS


To ensure more accuracy and consistency across its information collections, IRS is currently in the process of revising the methodology it uses to estimate burden and costs. Once this methodology is complete, IRS will update this information collection to reflect a more precise estimate of burden and costs.


  1. ESTIMATED ANNUALIZED COST TO THE FEDERAL GOVERNMENT


The Federal government cost estimate is based on a model that considers the following three cost factors for each information product: aggregate labor costs for development, including annualized start up expenses, operating and maintenance expenses, and distribution of the product that collects the information.


The government computes cost using a multi-step process. First, the government creates a weighted factor for the level of effort to create each information collection product based on variables such as; complexity, number of pages, type of product and frequency of revision. Second, the total costs associated with developing the product such as labor cost, and operating expenses associated with the downstream impact such as support functions, are added together to obtain the aggregated total cost. Then, the aggregated total cost and factor are multiplied together to obtain the aggregated cost per product. Lastly, the aggregated cost per product is added to the cost of shipping and printing each product to IRS offices, National Distribution Center, libraries and other outlets. The result is the Government cost estimate per product.


The government cost estimate for this collection is summarized in the table below.


Product

Aggregate Cost per Product (factor applied)


Printing and Distribution


Government Cost Estimate per Product

Form

$ 38,275


($0)


$ 38,275

Form Instructions

$ 19,547


($0)


$ 19,547

Grand Total

$57,822.00




$57,822.00

Table costs are based on 2018 actuals obtained from IRS Chief Financial Office and Media and Publications

* New product costs will be included in the next collection update.


  1. REASONS FOR CHANGE IN BURDEN


There have been no changes that would affect burden.


 

Requested

Program Change Due to New Statute

Program Change Due to Agency Discretion

Change Due to Adjustment in Agency Estimate

Change Due to Potential Violation of the PRA

Previously Approved

Annual Number of Responses

200,000





200,000

Annual Time Burden (Hr)

166,000





166,000



  1. PLANS FOR TABULATION, STATISTICAL ANALYSIS AND PUBLICATION


There are no plans for tabulation, statistical analysis, and publication.


  1. REASONS WHY DISPLAYING THE OMB EXPIRATION DATE IS INAPPROPRIATE


IRS believes that displaying the OMB expiration date is inappropriate because it could cause confusion by leading taxpayers to believe that the regulations sunsets as of the expiration date. Taxpayers are not likely to be aware that the Service intends to request renewal of the OMB approval and obtain a new expiration date before the old one expires.


  1. EXCEPTIONS TO THE CERTIFICATION STATEMENT


There are no exceptions to the certification statement.


Note: The following paragraph applies to all of the collections of information in this submission:


An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection of information displays a valid OMB control number. Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. 6103.

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