chc93

Interesting... I apologize for misinterpreting your question. I don't have any leads for your situation...

ftwilliam.com is totally web-based. Will work using any computer connected to the internet. Is this what you're asking for?

The attachment above describes PBGC Technical Update 07-03. Note that the PBGC has since issued Technical Update 08-4.

We've heard that the DOL started removing the signer name on the left side since TPA's names were appearing for those that file for their clients. So, we've seen prior filings which had names before, now show "Filed with authorized/valid electronic signature". But, at the recent ASPPA conference in LA, we heard that EFAST found that filing signer PIN's were not the correct ones for the signer, but was "accepted" anyway. So they are now going back to these filings where the PIN was entered incorrectly. If you're getting the "incorrect/unrecognized electronic signature", maybe the PIN was incorrectly entered when originally filed? As far as I know, we (our clients) have not received these IRS letters yet, and have not seen that "incorrect/unrecognized" note in the left side. I've gone back to a few filings on EFAST, and all have the "authorized/valid electronic signature" note in the left side... so far, no "incorrect/unrecognized" ones. Hope this helps...

This is interesting. In ftwilliam, I've got the DB plan codes in line 9a, and line 10h is blank, with no errors.

The ftwilliam software notes that "all defined contribution plans are individual account plans for this purpose even if they do not offer participant self direction", and therefore "10h cannot be blank" for DC plans. So we have completed line 10h for all of our DC plans.

It seems like Line 8b Other income (loss) is a reasonable place for the reversion. The "loss" can possibly be viewed as a "reduction of plan assets" rather than "investment loss". Also, I'm not sure Line 8j would be correct, since I thought that the reversion to the employer has to occur first, then the employer transfers to a qualified replacement plan which then reduces the excise tax.

I got this from the EFAST2 website. http://www.efast.dol.gov/fip/forms_pubs.html Near the bottom under Publications, the EFAST2 IFile User Guide. ************** 6.5.2.4 Create a New Filing by Replicating an Existing Filing A new filing can be created based on a previously submitted filing or an existing unsubmitted filing (i.e., a filing that was started in EFAST2 but not submitted). This is usually done to provide a starting point for the next year’s filing. Data is copied from the original filing based on the year of the new filing. If the replication is to the same year as the original filing, all data will be pre-populated. If the replication is to the next year, only demographic data will be pre-populated (see section 6.5.2 for a list of the demographic fields). Only the author of the original filing may replicate data from a previous filing. Only active, current year filings may be replicated; there is no replication of filings from an inactive year or prior year filings, even if they are an active year. For information concerning replication versus amendments, see the inset box in section 6.5, Creating a New or Amended Filing. ************** Hope this helps...

FTWilliam can store the DOL UserID (optional). But I don't think the DOL PIN can be stored, since it can't be shared?

For enrolled actuaries, I wonder what returns are included "within their limited practice areas". I would assume/hope that this would include at least the Form 5500 series...

I agree with Tom. Also, my experience with support from FTwilliam has been excellent. Emails have been answered well within an hour each time, even through the beginning of October. One time, I even got a call back from support to make sure that I understood the answers in the email. The actual electronic filing process was always "immediate" (within seconds) without problems (except for the clients who didn't quite follow instructions). FTwilliam also had a "notification" email sent automatically whenever a filing status has changed (like from "submitted" to "accepted" when the clients sign the form). p.s. One other thing I like is that the FTwilliam 5500 software system is entirely web-based. There is no software that needs to be downloaded to your computer, and all data are stored on their system. In fact, I had a problem once, emailed them, they fixed it in 15 minutes and let me know, and I could then continue. I was skeptical at first with the web-based nature, but got used to it and now really like it. Also because of this, you can work on forms, or view forms from any computer connected to the internet.

I don't know about getting it within IFile, but we did get an acknowledgement email from EFAST2 that the submission has been processed, which included the AckID. In fact, I really don't remember if there was a pop-up box after signing. One client came into our office and signed using a computer in our office. (EDIT: Daphne beat me...while I was typing...)

Agreed... same here.

I've recently had to look at the "short plan year" exception to attaching the IQPA report. In DOL 2520.104-50, it appears that the "accountant's report" and the "financial statements" are different, even if the requirements of the "financial statements" in ERISA section 103(b) appear to have all the requirements of an IQPA. I think maybe the difference is that the IQPA has the auditor's cover letter and signature. So if you're only attaching the "financial statements" but not a signed IQPA, maybe this is what it is. In any case, we've never done this... always had the signed IQPA.

I would amend the filing. It appears that if the client logs in to the DOL/EFAST2 site using his UserID and Password, he will see the history of all filings (original filing and amended filings). However, for public viewing, only the last (most recent) filing (amended) will display. Because of this, my thought is that the DOL/EFAST2 will only consider the most recent filing (amended and now correct). I hope I'm right on this.

I'm not sure I fully understand, and wanted to be clear on this. If the plan was properly frozen in 2002, such that all benefits were frozen and no new participants after the freeze date, and the plan was never top heavy, is there a coverage, 401a4, and/or 401a26 problem? I thought that in this situation, there would be no problems at all.

In our limited experience with only a few plans requiring audits, it is almost always the auditor's "fault". The are hired (or know they are hired) by the beginning of the plan year, and they get all the information the need by April or so, but don't start till mid-Sept or even later. Then it's a scramble...

What about a letter to the auditors that if the IPQA is not received by Oct 10 (or whenever), the auditors will be responsible for any late filing charges assessed by EFAST/DOL. (Maybe this should have been told to the auditors before they accepted the work, but might work for the future.)

But, doesn't each PTIN incur the $50-$100 annual fee? Was that an IRS suggestion? Sounds like extra cost (or revenue for the IRS) if "anyone and everyone" gets a PTIN. Thinking a bit more... the annual fee will only start later, so getting a PTIN now may not incur the fee... yet?

The ASAP also says that someone who performs "clerical and incidental services" is not a "preparer". My first thought when reading the ASAP was that this is a new "revenue source" for the IRS... annual fee of $50 to $100 to register for a PTIN?

My recollection from a few years ago... 1. small plan filing Form 5500 w/Sch I. can continue as small plan filing as long as participant count doesn't exceed 120. 2. large plan filing Form 5500 w/Sch H. must continue filing as large plan as long as participant count exceeds 100, and can continue filing as large plan as long as participant count remains larger than 80. (We've actually heard of a plan that dropped below 100 but wanted to file as a large plan so they could continue to require the independent plan audit -- don't know any other details.) So, if you were over 120 in the past and filed as a large plan, you can't change to a small plan filing until the count drops below 100, not 120. We haven't encountered this situation, but recall some discussion we had back then.

Tom, do you mean "filing signer" instead of "filing author"? We had a client register with the DOL as "filing author" only, and when trying to electronically sign and file the 5500, kept getting rejected, until client went back in to DOL and changed Profile to "filing signer".

Money Purchase Pension Plan terminated 4/30/2008. For 2009 Schedule R, can Part II - Funding Information be skipped. From the form istelf-- (If the plan is not subject to the minimum funding requirements of section of 412 of the Internal Revenue Code or ERISA section 302, skip this Part). My interest here is that the company went bankrupt, and there was a funding deficiency at 12/31/2008 (which will never be paid), and was disclosed on the 2008 Schedule R. For DB plans, I think there is agreement that a Schedule SB is not required in the plan year following the plan year containing the plan termination date, and I also think Part II on Sch R can be skipped for that following year, since the DB plan is not subject to 412 in that following year. Correct? Any ideas if Part II can be skipped for the money purchase pension plan in this following year similar to the DB plan (not subject to 412).

I thought I heard somewhere that Line #14 should be "truncated" to 2 decimals and not "rounded"... could that be it?

According to ASPPA, the IRS said that only the first 3 pages (but not the attachments) must be in the separate PDF file. Also, the IRS said that the actuary's typed name does not have to be on the signature line (only the initials are required) since the actuary's name is already provided on the Schedule SB/MB, and it was not intended that the actuary's name be typed twice on the form.