EFast 5500's
Form 5500 Electronic Filing Is Just Around the Corner!
When Congress passed the Pension Protection Act of 2006, it included a provision which requires that you file Form 5500 electronically. This new rule applies to every Form 5500 filing you make after December 31, 2009. However, paper copies for timely 2008 filings will be accepted through October 15, 2010.
Meet EFAST2
The new fully electronic processing system is known as EFAST2 and is scheduled to go live on January 1, 2010. Electronic filing applies to all Form 5500 reports filed for plan years beginning on or after January 1, 2009. It also applies to amended or late filings of prior plan year filings.
The first stop for you to interact with the new EFAST2 system is a feature known as I-REG (Internet Registration). You will need an Internet connection and an email address to sign up for credentials via the I-REG program.
Who Needs Credentials?
The person(s) who signs the face of the Form 5500 on behalf of either the plan sponsor or the plan administrator (or both) must apply for “signer” credentials using the I-REG system. All plan sponsors will receive a post card from the DOL, probably in January 2010, inviting them to apply for their credentials. There are a few important rules about these electronic credentials.
- Only one set of credentials will be issued for each email address. Signer credentials permit the user to sign as the plan sponsor, the plan administrator, or both.
- The credentials belong to you as an individual, not the business for which you work. Think of the credentials in the same way you think of your social security number (SSN) - the SSN always belongs to you, no matter where you work. For this reason, you will want to update your profile whenever your email address changes so that any notification from DOL is delivered to you in a timely fashion.
Where Do I Sign?
While the new system is referred to as a paperless system, that is only on the part of the government. Plan sponsors must maintain a fully executed (wet signature) copy of the Form 5500 with all schedules and attachments. If the filing is for a defined benefit plan, the wet signature copy of the actuarial schedule, Schedule SB or MB, must be part of the plan’s permanent records as well.
The electronic “signing ceremony,” as it is dubbed, will be a new process for you. In addition to signing a paper copy of the Form 5500, you will receive an email inviting you to link to our Form 5500 website. Here, you will be presented with a series of screens to act upon, thereby executing the signing ceremony. By inserting your User ID and PIN, you will sign the filing electronically.
What Do I Need To Do?
Markley Actuarial will be able to manage much of the transition to the electronic filing system for you. We’ll make sure you are ready to easily make the jump to electronic filing! Look for more information from us in the coming weeks.
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