EBSA Updates EFAST2 FAQs

• Question 23a: How do I enter special characters such as asterisk into the Plan Name, Sponsor Name, Administrator Name and/or DFE Name fields?The answer notes, "The only allowable characters for these fields are letters, numbers, commas, periods, hyphens, slashes, ampersands, percents, or single spaces. All other characters are currently invalid for these fields." While consideration is being given to expanding this list of allowable characters, the FAQ states other special characters will have to be omitted so the Form 5500 can be submitted and accepted.
• Question 24a: I only received one file from my Independent Qualified Public Accountant (IQPA) containing both the signed Accountant's Opinion (AO) and supporting Financial Statements. Do I need to separate this file into the AO attachment and the Financial Statements attachment? The answer acknowledges EFAST2 uses a system of "tags" to identify the required attachments to the Form 5500 filing, and that using the wrong "tag" can result in an error or warning message from the EFAST2 system. As such, the FAQ clarifies that if the IQPA report contains both the signed accountant's opinion and supporting audit report and financial statements then the entire IQPA report can be uploaded into the "AO" tag as a single PDF file. However, the FAQ also admonishes that a Schedule of Assets or Schedule of Reportable Transactions, if required, must be uploaded as separate documents into the appropriate tag. If both schedules are required but separate files are unavailable, the FAQ advises either uploading the same file into both relevant tags or creating a separate document explaining that the Schedule of Assets and/or Schedule of Reportable Transactions is included in the Accountant's audit report attachment and uploading that document into the appropriate tag(s).
• Question 24b: I only received one file from my actuary. Do I need to separate this file into the various attachments needed for the Schedule MB or SB? The FAQ advises these attachments must be uploaded separately, along with numerous other specified attachments that would be created by the plan actuary. However, "If you do not have software capable of splitting the file apart or cannot get separate files from your actuary, you may create separate documents with a brief statement that the required attachment is included in the Actuary Statement file, and upload the document where you would otherwise upload the required attachment using the correct tag for that attachment."

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