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Electronic Filing Mandate
What We’re Hearing About EFAST2 From Filers
and Stakeholders
What We’ve Done About It & The E‐Signature
Option
The Past Six Months & The Next Four Months
Registration Tips
Attachment Tips
Security Tips
Filing Completion Tips
Filing Submission Tips
EBSA
Electronic Filing Mandate
Plan Year 2008 Form 5500s can be
submitted on paper only through
October 15, 2010.
All other Form 5500s (Plan Year 2009,
2010, 2007 & prior) must be prepared &
submitted electronically to EFAST2
using EFAST2‐approved software or
IFILE.
Delinquent and amended Form 5500s
are not excluded from this mandate.
EBSA
What We’re Hearing
Some filers and preparers love EFAST2.
Others not so much.
• Generally folks who don’t like to use
computers or have Internet
connection difficulties
Most are figuring it out with some
assistance.
• Third party software, user guides,
interactive tutorial, FAQ
• Help Desk
EBSA
What We’ve Done
Spirit of continuous improvement with
resource constraints.
Provided public webcasts, participated
in speaking engagements, added to
FAQ, clarifying information on
webpages, and working on a Quick Start
Guide.
Provided E‐Signature Option for plan
sponsors/administrators who do not
electronically sign the Form 5500 or
5500‐SF.
EBSA
E-Signature Option
Plan administrator/sponsor must
provide written and signed
authorization to preparer that
acknowledges signature will be posted
on internet.
Plan administrator/sponsor must obtain
a printed copy of the completed
return/report and review it for accuracy.
If accurate, administrator/sponsor
manually signs the paper return/report.
EBSA
E-Signature Option, cont.
Preparer scans the signed paper Form
5500/5500‐SF and includes the PDF of
the first two pages as an attachment to
the electronic return.
Preparer provides the individual
electronic signature needed to submit
the return using Preparer’s own UserID
and PIN.
EBSA
For E-Signature Option,
Signature Posted on Internet
If the e‐signature option is used, the
plan administrator/sponsor’s manually
signature will be made available on the
EFAST2 website, as are all attachments
to the Form 5500.
EBSA
Other E-Sign Option
Considerations
Preparers must provide all
communication about the plan’s filing to
the plan administrator/plan sponsor.
Filing submitted electronically must
match the filing manually signed.
Only the two‐page signed Form 5500 or
5500‐SF should be attached to the
electronic filing as a PDF; not a copy of
the schedules and attachments.
EBSA
The First Six Months
~200K registered users.
>50K filings processed.
Just minutes to process filings.
>3K Help Desk calls each week.
Fewer filings have been submitted for
this time of year than normal.
EBSA
The Next Four Months
Filers who are waiting until close to
deadline are much likelier to have more
difficulty completing/submitting their
return
Take Away ‐ Don’t wait until October 15
to file. It may be harder to file.
Deadline for filing is midnight in plan
administrator’s time zone.
Help Desk hours remain the same
(8AM‐8PM ET) regardless of filing
EBSA
deadlines.
Registration Tips
You are registering for yourself, not a plan.
You only need to register one time regardless
of how many returns/reports you are signing
or submitting and for how many plans.
Roles explained by clicking question mark.
When in doubt, select Filing Author and Filing
Signer roles.
You can change your information, including
roles, or view your PIN at any time after
registration is complete by logging in.
EBSA
Attachment Tips
Don’t include old Form 5500 Schedule SSA,
new Form 8955‐SSA, social security numbers,
passwords, or other private information in
attachments to your 2009 and later filings.
Generally, these will be posted on the Internet.
Your account may be revoked.
Don’t scan your attachments unless it’s
necessary. If you must scan,
• Set your scanning resolution to 300 DPI.
• Optimize or reduce the resulting file size if
your scanner or PDF software has such a
function.
EBSA
Attachment Tips, cont.
Upload each attachment into the correct type.
If you have several hundreds of pages of
attachments for a single filing, IFILE may not
work well for you. Evaluate your needs and
see how third party software may better
support you.
EBSA
Security Tips
PDFs can not be encrypted or password
protected. They can be signed &
certified.
Don’t write down your
userid/password/pin and attach it in a
filing. We’ll revoke your credentials,
and you may lose access to your filings.
Stop including Schedule SSAs with your
Form 5500. If you need to file the SSA,
send those to the IRS in Odgen, UT.
EBSA
Filing Completion Tips
Turn off pop up blockers if using IFILE.
Validate before signing & submitting.
Otherwise, you’ll need to submit an
amended filing to fix errors.
The validation may point out
inconsistencies. The EFAST2 system
won’t necessarily point out the correct
answer, but you may be able to check on
your own. Call the help desk with
questions.
EBSA
Filing Completion Tips, cont.
If amending, you must send the entire
Form 5500 including all schedules and
attachments.
When your return/report is all filled out
(complete), you should export an
electronic copy of the filing for your
records.
EBSA
Filing Submission Tips
Be sure to check the status of your filing after
submission. It should say “Filing Received”
Click to see if there are errors or warnings.
If the status is “Filing Received” and no
warnings are listed, you do not need to do
anything further unless you receive follow‐up
correspondence from a Government agency.
If the status is anything other than “Filing
Received,” correct the errors or warnings listed
and submit an amended return to avoid
potential correspondence and imposition of
penalties.
EBSA
Review & Wrap Up
Electronic Filing Mandate
What We’re Hearing About EFAST2 From
Filers and Stakeholders
What We’ve Done About It & The E‐Signature
Option
The Past Six Months & The Next Four Months
Registration Tips
Attachment Tips
Security Tips
Filing Completion Tips
Filing Submission Tips
EBSA
Form 5500/5500-SF
Who Files and What to File
Rules mostly unchanged on who files and
what
BUT people are more aware that they may
have had a filing requirement and are now
asking the basic questions
Biggest change on who and what:
• 403(b) plans now report like other pension
plans
• New Form 5500‐SF for eligible small plans
What to file for large welfare plans clarified in
instructions
EBSA
Getting Started
Do I have to file?
Can I file the Form 5500‐SF?
What schedules do I have to complete?
What questions on the Form and Schedules do
I have to answer?
EBSA
Where to Get Answers
General instructions, including “Quick
Reference Chart.”
Questions and text on face of Forms and
Schedules.
Instructions by Form and Schedule.
Additional Guidance:
• Regulations referenced in instructions.
• FAQs.
• Guides and tips.
EBSA
Pension Plans—Who Files
Most private employer‐sponsored pension
plans have to file either the Form 5500‐SF or
the Form 5500 and its schedules and
attachments
Which form and which schedules depends on
size, nature of plan’s investments, plan
activities during the year, and type of plan
Some plans are exempt from filing
EBSA
Pension Plans that Don’t File
Unfunded excess benefit plans
Plans not covered by Title I of ERISA
403(b) plans that meet the terms of DOL’s
“safe harbor” regulation at 29 CFR 2510.3‐
2(f)
Church pension benefit plan not electing
coverage under Code section 410(d)
Foreign plans
Governmental plans
IRA’s or annuities not considered plans
under 29 CFR 2510.3‐2(d)
EBSA
Pension Plans that Don’t File,
cont.
SEPs that meet the alternative method of
compliance in 29 CFR 2520.104‐48 or 49.
Unfunded dues financed pension benefit plan
that meets the alternative method of
compliance in 29 CFR 2520.104‐27
EBSA
Limited Reporting for Certain
Pension Plans
Limited Reporting:
• IRA Plans using individual retirement
accounts or annuities (as described in Code
section 408)
• Fully insured pension plans
EBSA
5500-SF Eligible Small Pension
Plans – What to File
Form 5500‐SF eligible:
• Form 5500‐SF
• No schedules or attachments except:
Schedule MB for money purchase plans;
Schedule SB for defined benefit pension
plans.
• If electing e‐signature alternative, attach
PDF of manually signed Form 5500‐SF to e‐
filing.
EBSA
Small Pension Plans Not 5500-
SF Eligible – What to File
Form 5500 (including PDF of manually signed
5500 if using e‐signature alternative)
Schedule A, if applicable, for insurance
information
Schedule D, if applicable, for info on
investments in DFEs
Schedule G, if applicable, to report non‐exempt
transactions
Schedule I for financial information
Schedule R for retirement plan information
EBSA
Small Pension Plans Not 5500-
SF Eligible – What to File, cont.
Schedule MB only for multiemployer defined
benefit plans and money purchase plans
Schedule SB only for single employer defined
benefit pension plans
If meet the requirements of 29 CFR 2520.104‐46
(small plan audit waiver regulation) don’t need
to file IQPA report.
EBSA
Large Pension Plan Filing—
What to File
Form 5500 (including PDF of manually
signed 5500 if using e‐signature alternative)
Schedule A, if applicable, for insurance
information
Schedule C for service provider
information
Schedule D, if applicable, for information
on investments in DFEs
Schedule G, if applicable, to report non‐
exempt transactions
Schedule H for financial information
EBSA
Large Pension Plan Filing—
What to File, cont.
Schedule R for retirement plan information
Report of independent qualified public
accountant
Schedule MB if money purchase plan or
multiemployer plan
Schedule SB if defined benefit pension plan.
EBSA
Basic Attachments
Report of the Independent Qualified Public
Accountant
For defined benefit pension plans, PDF of
manually signed Schedule MB or Schedule SB
EBSA
Only Certain Welfare Plans File
Most large private welfare plans file, but only
certain schedules.
Generally, only those small (under 100) welfare
plans funded by a trust or VEBA have to file.
EBSA
Welfare Plans that Don’t File
Small welfare plans (those that covered fewer
than 100 participants as of the beginning of the
plan year) that are unfunded, fully insured, or
a combination of insured and unfunded.
Foreign plans
Governmental plans
Unfunded or insured welfare plans maintained
for a select group of management or highly
compensated employees, that meets 29 CFR
2520.104‐24
EBSA
Welfare Plans that Don’t File,
cont.
Welfare plans that participate in a GIA that
files a Form 5500 on behalf of the plan as
specified in 29 CFR 2520.103‐2.
Church plans
Plans maintained solely for (1) an individual or
an individual and his/her spouse or (2)
partners and partners’ spouses in a
partnership.
EBSA
Large Welfare Plans—What to
File
Plans funded with a trust or VEBA
Form 5500(including PDF of manually signed
5500 if using e‐signature alternative)
Schedule A, if applicable, for insurance
information
Schedule C for service provider information
Schedule D, if applicable, for information on
investments in DFEs
Schedule G, if applicable, to report non‐exempt
transactions
Schedule H for financial information
IQPA report
EBSA
Large Welfare Plans—What to
File, cont.
Fully insured/unfunded or combination that
meet requirements of TR 92‐01 and 29 CFR
2520‐104‐44
Form 5500 (including PDF of manually signed
5500 if using e‐signature alternative)
Schedule A, if applicable, for insurance
information
Schedule G, if applicable, to report non‐exempt
transactions
EBSA
Direct Filing Entities (DFEs)
DFE is a trust, account, or other investment
arrangement in which plans participate, which
files its own Form 5500.
Master Trust Investment Accounts must file a
Form 5500.
CCTs, PSAs, 103‐13IEs, and GIAs may, but are
not required to file a Form 5500.
• If they file, plans investing in these
arrangements get certain reporting relief.
• More information on filing requirements for
DFEs in the instructions.
EBSA
DFVC Program
Delinquent Filer Voluntary
Compliance Program
DFVC Program
Reduced penalties for late/non‐filed 5500s
• Small Plans = $750/filing or $1500/plan
• Large Plans = $2000/filing or $4000/plan
IRS will waive their penalties upon
participation in program
Only Form 5500 filers are eligible
• No Form 5500‐EZs
• No Form 5500 SFs for 2008 or earlier years
EBSA
DFVC Program
Still a 2 Step Program!
Submit original filings electronically
• Only the 2008 may be filed on paper
• ALL other years must be electronic
Submit to DFVC Program 1 of 2 ways
• Electronically using E‐Pay
• On paper through the mail
EBSA
Questions
EBSA