EFAST 5500 and the Schedule P

[Guest PAINPA]

We prepare a Schedule P for each trustee of the plan. I noticed that some TPA's complete only a single Schedule P with the 3 trustee names on the 1 line. Previous reviews of this process end in a split vote. My theory is why would the software allow multiple schedule P's then.

However, In regards to EFAST signatures, do I need to obtain 3 EFAST signature ID's? The reason I ask is in Relius Gov't Forms, when electronically filing, the software will only extract the names on the 5500 (plan administrator & Plan Sponsor/employer, if they are different) regardless of how many trustee's (Schedule P's).

Do I even need EFAST signatures for the Schedule P?

[Guest anonymous coward]

Here's some sources for you:

Sch. P instructions (5500 Instruction Manual, 2002, p50)

"Shedule P (Form 5500) may be completed by every trustee of a trust created as part of an employee benefit plans as described in Code section 401(a), and by every custodian of a custodial account described in Code section 401(f)...If the trust or custodial account is used by more than one plan, file one Schedule P. If a plan uses more than one trust or custodial account for its funds, file on Schedule P for each trust or custodial account." Also, see the section on the signature, which states pretty clearly, "The fiduciary (trustee or custodian) must sign this schedule. If there is more than one fiduciary, the fiduciary authorized by the others may sign."

Here's how I read that: One trust account = one Sch. P, One trust account + multiple trustees = One Sch. P + One signature (provided that person is authorized by the others to sign on their behalf)

As for the electronic filing, you can reference page 31 (Rev. 3/1/03 Section 13) of the EFAST-A publication:

"Use of the PIN and Signer ID as electronic "signature" certifies that all required signatures are on file in the plan's records including all of the following items that are applicable: a signed original Form 5500 or 5500 EZ (Plan Administrator, Plan Sponsor, Plan Sponsor/employer and Signer), AR/AO (certified public accountant), Schedule B (actuary), Schedule P (fiduciary), and Schedule SSA (Signer)."

How do I read that? When filing electronically, the only signature that need an EFAST-1 filed for are the Plan Administrator and/or Sponsor/Employer signatures. The rest of the forms and schedules are sent as is electronically (Sch. B, P, SSA, etc.) without electronic signatures, providing there are signed originals on file in the plan's records.

(I also see multiple schedule P's all the time for filings when plan assets are switched b/t financial institutions mid-reporting year.)