The IRS released Announcement 2011-21, designating that Form 8955-SSA, Annual Registration Statement Identifying Separated Participants with Deferred Vested Benefits, generally must be filed by the last day of the seventh month following the close of the plan year. For calendar year plans, the deadline is July 31, with extensions. This is the same filing deadline (and extensions) as Form 5500. Form 8955-SSA replaces Schedule SSA of Form 5500 beginning with the 2009 plan year. Announcement 2011-21 includes special due dates for the 2009 and 2010 plan years. The due dates for the 2009 and 2010 plan year Forms 8955-SSA are the later of (1) the due date that generally applies for filing the Form 8955-SSA for the 2010 plan year, and (2) August 1, 2011. The IRS expects to have the year 2009 Form 8955-SSA available shortly for plans to access and complete. Plan administrators will be permitted to use the 2009 form for year 2010 reporting, pending release of the 2010 Form 8955-SSA. The IRS also expects to have ready a voluntary electronic reporting option for this form.

The IRS also provided relief for plan administrators who have submitted to the IRS a Form 5500 Schedule SSA for the 2009 and 2010 plan years. The IRS will treat a Schedule SSA that is filed with the IRS for the 2009 and 2010 plan years by April 20, 2011 as satisfying reporting requirements, and no Form 8955-SSA will be required to be filed for those plan years.