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Guest Article

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(From the August 23, 2010 issue of Deloitte's Washington Bulletin, a periodic update of legal and regulatory developments relating to Employee Benefits.)

EBSA Updates EFAST2 FAQs


The Department of Labor's Employee Benefits Security Administration has updated its "Frequently Asked Questions" (FAQs) on the EFAST2 electronic filing system for the Form 5500. All Form 5500 filings for plan years beginning on or after January 1, 2009 must be filed electronically using EFAST2. The updated FAQs include the following new questions:

  • 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."

Additionally, Question 11 has been updated to clarify the definition of "Filing Signer" and Question 29 has been updated to address a potential issue with "optimizing" PDF files. These updated FAQs may be found on the Department of Labor's Web site, at www.dol.gov/ebsa.


Deloitte logoThe information in this Washington Bulletin is general in nature only and not intended to provide advice or guidance for specific situations.

If you have any questions or need additional information about articles appearing in this or previous versions of Washington Bulletin, please contact:

Robert Davis 202.879.3094, Elizabeth Drigotas 202.879.4985, Mary Jones 202.378.5067, Stephen LaGarde 202.879-5608, Bart Massey 202.220.2104, Tom Pevarnik 202.879.5314, Sandra Rolitsky 202.220.2025, Deborah Walker 202.879.4955.

Copyright 2010, Deloitte.


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