Bug on my window

Yes, as per the instructions e-filing the extension is now an option through EFAST. https://www.irs.gov/pub/irs-pdf/f5558.pdf or you can see this on the "new and noteworthy" section of the https://www.efast.dol.gov/ page.

The audit is for the plan, and so it gets attached to the Plan's 5500. The Master Trust Investment Account filing is considered part of the Form 5500 for the Plan, but it is not itself required to attach an audit report.

Hi Folks, My client is using Relius (I'm not) and they are telling me they can't override the Schedule SB calculation of box 10b. Any Relius users out there? Can you tell me if this is realistic? Thanks for reading

Where do you see the DOL template that includes the blurb?

I agree with Paul's comment with one additional perspective. I have seen many Form 5500s submitted with non-zero Schedule A headcounts for final 5500s. The reasoning I've seen given is that 1. Participants are covered on the last day of the contract year (but not any day afterwards), and 2. There is no requirement for a final filing that the Schedule A count be zero and 3. This is the data as it is provided from the carrier on the Schedule A, and they don't have a good reason to change it. Just my $0.02. Take it for what it's worth, someone's opinion on the internet. :)

When is the wrap effective? Is the wrap going to be a continuation of one of the existing plans? If it's 12/31/prior-year, and the new plan is effective 1/1/current-year, then you will have final 5500 filings needed for all plans that are not continuing. The Prior Year 5500 will need to show zero headcounts at year end (as all final filings do) and have the final filing box checked. If the wrap will be effective 1/1/current year, instead of 12/31, then I believe you are setting yourself up for a one-day 5500 filing. Note that the Schedules A follow the same rules as always. They should be included for the plan year that ends within the contract year. Other folks smarter than I may have other opinions. Take this for what it's worth, free advice.

Also if there's no trust-funded assets then there's no requirement under the 5500 instructions to audit the plan.

An HRA provides medical care, so as far as I understand, yes they would be reportable under ERISA. Are they trust funded (VEBA)?

As I understand it (and I'm not an expert at all!) it's how the contract is arranged with the insurance carrier. So yes, it's a choice. Here's an article I found that talked about experience-rating from the perspective I've seen it. Group insurance premiums are adjusted, not year over year, but based on comparison to another similar group. https://www.investopedia.com/terms/e/experience-rating-insurance.asp

I always understood that a trust should have its own EIN, for purposes of any tax filings required for the trust. This article has some thoughts on the matter. https://www.policygenius.com/trusts/ein-for-a-trust/ Also the DOL specifies the "EIN of the Trust" in this language. They also refer to how you can use the next Plan Number in the series. https://www.dol.gov/agencies/ebsa/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/forms/efast2-form-5500-filing-tips#:~:text=In the case of a Form 5500 filed,Investment Entity (IE) or Group Insurance Annuity (GIA).

It went offline earlier this year. The IRS announced on 11/7 that they would be offline starting November 25th at 6pm EST through January 6. https://www.irs.gov/e-file-providers/filing-information-returns-electronically-fire

Based on this, would you agree that the deadline for a Form 5500 extended to April 15 (plan year end of 6/30/2021) is due April 18th?

I'm not sure I follow. A pooled separate account is a direct filing entity sponsored by an insurance carrier. As a result I would expect a Schedule A for a PSA, as well as an entry on the Schedule D. Here's some reading I found through Mr. Google https://www.sapling.com/4709056/what-direct-filing-entity

https://www.asppa.org/news/%E2%80%98missing-form-5500%E2%80%99-email-legit

did you try calling the DOL EFAST help number? 1-866-GO-EFAST?

The DOL Form Selector Tool should tell you. Most of the forms will likely need the 2021 version, with some exceptions. https://www.askebsa.dol.gov/FormSelector/ I know some e-filing software tools allow you to download the data electronically (so, download the 2018 data) and then upload the data electronically again (into 2021) so hopefully that saves you a step for typing it up?

I don't have experience with your particular case however I am aware that occasionally the plan year on the IRS' confirmation response does not match the plan year filed. In other such cases, I've seen plan sponsors respond directly to the IRS by phone and mail, providing a copy of the actual 5558 filed showing the correct information.

Hi Folks, I'm looking for some input from folks smarter than me. How will auditors look at plans with post-10/15 contributions for the 2019 plan year? Specifically, I'm assuming that these contributions are not reported on the 2019 SB (since they haven't been made yet) as of the time of filing. Will they be left off of the audit report? Included as a footnote? If the plan sponsor amends the filing post-10/15 to include the contributions on the SB, will the H/audit also require amendment? Thanks for your thoughts on this! Bug

Is this information about the processing center being shut down posted somewhere I can verify? Are you still sending in 5558s?

Can you provide more detail on this, specifically the plan sponsor's reasoning for not using the DFVC? Are they currently under review by a federal agency?

Can you tell us where you heard about updates?

The trustee must recognize that the two pools of money are separate, so they can make the annual ERISA statements each year for each separate pool. As a side note, I understand that splitting a plan solely to avoid the audit requirement is not looked upon favorably. Is there another reason/division for the split? Some natural division between two groups that are getting different benefits?

It seems to me that if you are creating a wrap plan anyway, for 5500 purposes it shouldn't matter if you do two separate plans or one. There may be other reasons to not include the ancillary benefits into the wrap that the lawyers who lurk here may have something to say about.

I think you should try to file what you have now, now. Can we hear more about this, "do it again in a year or so or whenever the 2016 and 2017 5500s are ready to file"? If it's going to be such a long time, then it sounds like the 2016/2017 forms are not being worked on with all expediency....do you know what's causing the hold up? I understand Bob the Swimmer's position - however I also understand that filing some years (but not others) under the DFVCP doesn't automatically garner you attention for an audit - otherwise, what's the point of the correction program? If it was just used to catch people, then that would discourage people from using it. Based on how the DOL talks about the DFVCP, it seems to me that they would prefer everyone would simply correct themselves as soon as possible rather than file incorrectly (and in this case, correct what you can, work on the others when you can).

chc93, I've seen this happen as well. However the important point being that if it's not done within the 45 days there will be consequences. In the case I'm thinking of, the plan sponsor's audit report wasn't done on the deadline, and it was just *barely* able to be finished by the 45 day mark. I agree with MoJo, my preferred option is to have the plan sponsor file late under DFVC. It's just not worth it.