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Electronic Signatures?


Gilmore

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As far as I know, the only electronic signature that the DOL will accept is using EFAST credentials. I know at least one frequent poster on this forum has his own particular interpretation of what that means.

Here is what the 5500 instructions say about service provider signatures (emphasis added):

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Authorized Service Provider Signatures. A statement for service providers that use this electronic signature option is in the IFILE application. The statement provides that, by signing the electronic filing, the service provider is attesting: (1) that the service provider has been authorized in writing by the plan administrator, plan sponsor/employer, or DFE, as applicable, to electronically submit the return/report; (2) that a copy of the specific written authorization will be kept in the service provider’s records; (3) that, in addition to any other required schedules or attachments, the electronic filing includes a true and correct PDF copy of the completed Form 5500 (without schedules or attachments) bearing the manual signature of the plan administrator, employer/plan sponsor, or DFE, as applicable, under penalty of perjury; (4) that the service provider advised the plan administrator, employer/plan sponsor, or DFE, as applicable, that by selecting this electronic signature option, the image of the plan administrator’s, employer/plan sponsor’s, or DFE’s manual signature will be included with the rest of the return/report posted by the Department of Labor on the Internet for public disclosure; and (5) that the service provider will communicate to the plan administrator, employer/plan sponsor, or DFE, as applicable, any inquiries and information received from EFAST2, DOL, IRS or PBGC regarding the return/report.

 

Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance.

Corey B. Zeller, MSEA, CPC, QPA, QKA
Preferred Pension Planning Corp.
corey@pppc.co

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Just to clarify because I should have been clearer originally, I'm referring to the copy that either the plan keeps in their files or gets uploaded along with the electronic filing if filed by a third party.

I'm thinking along with you C.B. that manual signature means you signed it in ink, but I'm getting old and what is defined as a "manual" signature may have gone right past me, especially with the rule bending for the pandemic.

Thank you.

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When the plan’s administrator is an organization (for example, the corporation, limited-liability company, or registered partnership that is the plan’s sponsor), does anyone affix as the signature, however “manual”, a signature of the organization’s name—for example, Worldwide Widget Company—rather than a human’s name?

 

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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