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Can one file 5500-EZ before SB is signed?


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Yes, the 5500EZ instructions say that the SB must be completed before the filing due date, not the filing date itself.

"If the plan is a defined benefit plan, the enrolled actuary 
must complete and sign the 2021 Schedule SB (Form 5500) 
and forward it no later than the filing due date to the person 
responsible for filing Form 5500-EZ."

You may have to amend based on your reported 10a vs the completed SB.

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This is what the Form 5500-EZ says right above the signature line:

Quote

Under penalties of perjury, I declare that I have examined this return including, if applicable, any related Schedule MB (Form 5500) or Schedule SB (Form 5500) signed by an enrolled actuary, and, to the best of my knowledge and belief, it is true, correct, and complete.

So I don't see how a plan administrator could sign a 5500-EZ before the Schedule SB has been signed without perjuring themselves.

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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