Provided by your plan administration partner:
EBSA Requires all 5500's to be filed electronically after 1-1-2010
It's not 100% official yet, but here's what we've been told:
Be aware the DOL/EBSA will send you a postcard in January indicating your requirement to file electronically. IPSD will be keeping track of system availability and will guide you through all the necessary steps. You can see the steps in list form here
When is the mandatory electronic filing system (EFAST2) effective?
The EFAST 2 is effective for plan years beginning on or after January 1, 2009. Plans will be able to begin filing electronically on January 1, 2010.
Are any plans exempt from an electronic filing?
5500-EZ filers are NOT required to file electronically (EZ's are filed by Plans with no common law employees other than the owner (partner owners) and their spouses.)
How does a plan sponsor obtain electronic signature credentials?
Your Customer Service Representative (Meghann or David) will call to walk you through this process. It will take 2 calls. The first call will be to identify the people who will act for the Plan Sponsor and Plan Administrator. The second call will be to take this information and help each designated person walk through the DOL website and get their credential. One person CAN sign as Sponsor and Administrator.
May a TPA obtain signer credentials on behalf of its clients?
No. Every individual who signs a 5500 or schedule must obtain his/her own signature and the limit is one set of credentials per email address. When an individual obtains signer credentials, the individual must certify to the government that he/she will not share the credentials with anyone, including a TPA.
How do I use the electronic signature credentials in filing a Form 5500 electronically?
Innovative Pension will invite the plan sponsor to an electronic signing ceremony where an authorized representative (e.g., officer) of the plan sponsor will enter his/her credentials. Your Customer Service Representative will call to walk you through this process.
May a preparer or plan sponsor use the same email address to obtain credentials for more than one person?
No. The DOL limits one set of credentials to an email address.
Under IFILE, will a preparer be able to invite the plan sponsor official who will sign the Form 5500 to the electronic signing ceremony if the official does not have signer credentials?
No. We need to make sure you get your credentials in advance of your 5500 being ready to file. Please cooperate with our CSR's when they call to help you get your credentials
When will IREG website (place to get your credentials)be available?
January 1, 2010. (We hope – no guarantees yet)
Will a plan sponsor electronically file attachments and plan audits (attachments)?
Yes. If a Form 5500 filing (or schedule) requires attachments, the preparer must file the attachments electronically. The DOL accepts the portable document format (PDF electronic formats)
Under EFAST2, what requirements apply to the accountant's opinion?
Under EFAST2, the accountant's opinion must be on the accounting firm's letterhead with the firm's name, address and phone number. The opinion must also include a "wet" signature of the accountant.
Plan Sponsors that attempt to file without the opinion, will immediately have the entire filing rejected. Therefore, Innovative Pension will request that all accountants complete their audits prior to October 1 (or first day of the 10th month after Plan Year End)
How will the DOL prevent a preparer from filing a Form 5500 without the accountant's opinion?
EFAST2 will have a "node" in the electronic filing structure that must include the opinion. If the filing does not contain the opinion in the node, the system will not accept the filing. Also, the DOL will be aware that a filing is late immediately following the deadline and can send out letters assessing penalties immediately.
Will the Schedule B require a "wet" signature on the part of the actuary?
Yes. The actuary will prepare the schedule, print it, and include the wet signature, then will need to scan the schedule into PDF format to be attached to the filing. The actuary also will need to provide the schedule in electronic format. Accordingly, the filing will include both an electronic and PDF version of the schedule. Note: The Board of Actuaries determined that the schedule needed a wet signature.
Reach Meghann or David, your Customer Service Representatives at 858-748-6500 with questions.
Plan Design 858-218-3440
Contact Us
Please note: Your Customer Service Representative is ALWAYS your first point of contract for anything you need to know from our firm. Please contact them with your questions.
In this Announcement:
Update on Electronic 5500 Filing
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Innovative Pension
14251 Danielson Street
Poway, CA 92064
For Assistance,
Call Customer Service: 1.800.98PENSION
or email helpdesk