The American Retirement Association wrote to the Internal Revenue Service to respond to the request for comments on the proposed compliance questions for the Form 5500 series. The letter recommended that the effective date for the mandatory collection of information solicited by the new compliance questions be delayed to coincide with the proposed Department of Labor Form 5500 revisions expected for the 2018 or 2019 plan year forms. In addition, the letter recommended that the mandatory collection of the plan trust’s EIN be delayed for at least the next two plan years to provide time for plan sponsors to determine whether a trust EIN has been deactivated by the IRS or apply for an EIN.