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  1. A BenefitsLink discussion yesterday remarked on a service provider’s request for a nonelectronic signature, despite an IRS procedure that permits an electronic signature. There is no one comprehensive rule that answers questions about the acts or circumstances that require a manual, rather than an electronic, signature. For some of us, it’s not easy to recall which acts (of those that call for a plan sponsor’s or plan administrator’s signature) permit an electronic, or require a “manual”, signature. So, let’s crowdsource our list. The focus is on what the three U.S. government agencies—the Treasury department’s Internal Revenue Service (IRS), the Labor department’s Employee Benefits Security Administration (EBSA), and the Pension Benefit Guaranty Corporation (PBGC)—say is permitted or required. If you quickly remember it, next to each description put the abbreviation for the agency that stated a rule or guidance. I’ll start by putting one entry in each category. Manual signature required A plan’s administrator authorizing its service provider to submit the administrator’s Form 5500 report — EBSA — source ??? . . . . . . . . . . . . Electronic signature permitted A user’s signature to adopt an IRS-preapproved plan document — IRS — Rev. Proc. 2017–41 § 5.10, 2017-29 I.R.B. 92, 99 (July 17, 2017), https://www.irs.gov/pub/irs-irbs/irb17-29.pdf . . . . . . . . . . . . We invite your BenefitsLink neighbors’ praise if you help us complete this list.
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