Electronic Filing

[Gary]

I mail hard copies of the form 5500 to all our clients (originals and copies). It is extremely tedious.

Is anyone out there filing FOrm 5500 electronically? I haven't even had the chance to research that option.

If so, how is it going?

I believe it becomes mandatory in 2009.

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What is the concensus re: Form 1099R? Are TPA's doing it for clients or are TPA's leaving it in the hands of the plan sponsor to provide to ditributees? I have a lot of mom and pop plans with very few employees and they may not want to be bothered with this.

Curious to hear how others' handle that as well.

Thanks.

[Lori Friedman]

I e-file quite a few Form 5500's. One of my firm's clients has 15,000 names on its 2007 Schedule SSA; another client has 5,200 names -- can you imagine even trying to file those returns on paper?!?! I've been e-filing for about 3 or 4 years, so far with no problems whatsoever.

Clients are usually squeamish about electronic filing until they've tried it. Then, they prefer e-filing to paper filing. There's no need to worry about getting signatures, and there aren't any last-minute rush trips to the post office.

[pmacduff]

I posted this back in November of 2007 and received no responses...Lori????

"I have a small client who always waits until the last minute to get us the information to complete the 5500 form for his Profit Sharing Plan. (yeah I know, one of MANY small clients, actually). In any event, this particular client wants me to set him up with EFAST filing so that we don't have the worry about getting him the form timely to physically sign and file by midnight on October 15th.

I know that the EFAST-1 form needs to be filed, I assume by the client? Would I then be able to file his return from my office if he provided me with the password data he receives? Is there a way for us as a TPA to obtain authorization as TPA?

We obviously don't sign any of the 5500 forms which leads me to believe that for now anyway, each client that wants to do this must be set up individually, is that correct?

I figured with everything going the e-filing way in the future, it is time to start this with some of our smaller clients so that we can get the feel of how this works before it is required.

Any thoughts appreciated. "

[Lori Friedman]

I know that the EFAST-1 form needs to be filed, I assume by the client? Would I then be able to file his return from my office if he provided me with the password data he receives? Is there a way for us as a TPA to obtain authorization as TPA?

Both the transmitter (your TPA firm) and the signatory (the person who signs Form 5500) are required to file a Form EFAST-1.

First, you'll want to confirm that your Form 5500 program is from an approved software developer and can support e-filing. Then, your TPA firm files a Form EFAST-1 to apply for a transmitter's Electronic Filing Identification Number (EFIN) and password. You can't e-file any Form 5500's without EBSA approval and this electronic filing information.

Finally, every Form 5500 signatory needs a Signer ID and PIN. Each individual files Form EFAST-1 to request this information. If the application form provides your own name and email address as the contact person, EBSA will send the information directly to you.

We obviously don't sign any of the 5500 forms which leads me to believe that for now anyway, each client that wants to do this must be set up individually, is that correct?

Yes, the Signer ID and PIN are unique to an individual signatory. The information "belongs" to the person, not to the plan. Someone who signs multiple Form 5500's will use the same Signer ID and PIN for all plans.

[pmacduff]

Thanks Lori, that's most helpful! Again we're a small operation but want to get a jump on this before it is mandatory.

[chc93]

A question came up today regarding the electronic signature. The Form 5500 says the person signing the form "under penalties of perjury" declares that he has examined the return/report, as well as the electronic version of the return/report, and believes it to be true, correct, and complete. How does he sign the EFAST-1 before he has a chance to review the Form 5500. Does this mean that we first get him to sign the EFAST-1, then send him the Form 5500 when completed to get his approval, and then we can file electronically? Obviously the big concern is those clients that wait to the very last minute. We're interested to know how others are handling this. Thanks...

[Lori Friedman]

How does he sign the EFAST-1 before he has a chance to review the Form 5500. Does this mean that we first get him to sign the EFAST-1, then send him the Form 5500 when completed to get his approval, and then we can file electronically?

Form EFAST-1 is separate from and independent of Form 5500.

First, the plan's signatories file Form EFAST-1 to obtain their own Signer ID's and PIN's. This information is unique to each individual and doesn't "belong" to any specific plan. Later, when you prepare Form 5500, you'll want to provide a copy of the return (on paper or PDF) for your client's review and approval. When you have the greenlight to e-file Form 5500, you create an electronic version of the return and input each signatory's name, Signer ID, and PIN.

I highly recommend that you get written documentation of the e-file approval and keep it on file. An email message from the client is fine.

[chc93]

First, the plan's signatories file Form EFAST-1 to obtain their own Signer ID's and PIN's. This information is unique to each individual and doesn't "belong" to any specific plan. Later, when you prepare Form 5500, you'll want to provide a copy of the return (on paper or PDF) for your client's review and approval. When you have the greenlight to e-file Form 5500, you create an electronic version of the return and input each signatory's name, Signer ID, and PIN.

I highly recommend that you get written documentation of the e-file approval and keep it on file. An email message from the client is fine.

Thank you. This is what we thought the process should be.