Service provier signing on behalf of employer/sponsor

[Moe Howard]

I use CCH Prosystem-Fx to prepare income tax returns and a few 5500s. CCH will be the "Transmitter" of the 5500s that I prepare.

I just received written authorization from plan's sponsor, giving me permission to electronically sign & file the 2009 Form 5500 on its behalf.

Now I'm ready to go to EFAST2 online and register for PIN & ID numbers.

Am I supposed to obtain a PIN & ID as "filing Author" and also a separate PIN & ID as "filing Signer" ?

What name (my name or employer/sponsor name?) am I supposed to register the "filing Signer" PIN & ID under ?

[Tom Poje]

I think you only need filing signer

in the end, your name will appear on the left side of the 5500 (the 'sign here' spot) while the client's name will appear on the right side

(if you are real smart, when you get back you ID back from the DOL you will print out and put in a spot you wont forgot.

[Mike Preston]

I recommend "Password Safe", an open source free program that fits "just right" for things like this. You can set up a master password that is a strong, yet easy to type, and have complete confidence that the information stored is protected (of course it is encrypted). I have nearly 300 entries in mine and it covers everything from logons at various websites (link benefitslink) to social security numbers of family members.

[Moe Howard]

Tom, are you sure that my name should appear somewhere on the 5500 hard copy ?

I won't be wet-signing the 5500 hard copy. I will be entering the client's (filing signer) PIN & ID into the electronically filing process.

The client has to wet-sign a hard copy of the 5500 and I have attach that wet-signed hard copy to the electronically filed 5500.

When I register for a "filing signer" PIN & ID # do I use my name & personal profile data or do I use the client's.

[Tom Poje]

according to the instructions, it is the form preparer who registers for signing credentials, you are not registering at the DOL to obtain credentials for the client. I suppose you could and who would know, but then why would you need to attach a signed copy? Hopefully the DOL will add the verbage on the form to indicate 'electrinically signing on behalf of...

The new signing procedure requires the following steps:

1. The plan sponsor/administrator must sign the completed 5500 form on paper.

2. The plan sponsor/administrator must sign an authorization to have the preparer electronically sign the 5500 on their behalf

3. The form preparer must register for signing credentials at the DOL EFAST2 registration website .

4. The form preparer must attach a copy of the first two pages of the signed 5500 as an "other" pdf attachment to the electronic filing.

5. The form preparer must electronically sign the 5500 using the PIN received from the DOL website.

at least that is my understanding of how it works. someone else here reported similar results.

[Moe Howard]

Tom, thanks. Now I understand.

Neither my name nor my signature will appear on my clients' 5500.

I'll have to obtain my own "filing signer" pin & ID from the EFAST2 website to electroniclly sign on my clients' behalf. I'll use that pin & ID # to electronically file clients' 5500, that I prepare. I'll use my name and persoanl profile data when I register for that "filing signer" pin & ID.

Client's will have to sign a paper 5500, which I will attach to the electronic filing.

ONE LAST QUESTION:

I myself am an employer. I am the sponsor/administrator of my own firm's PSP. Can I use the same "filing signer" pin & ID # on my clients' 5500 (when I file on their behalf), that I use on my own 5500 when I sign as sponsor ?

[Tom Poje]

that would be my understanding

[Tom Poje]

Moe:

I see the DOL website now contains the filing blurb

The EFAST2 electronic filing system allows the plan administrator to authorize a practitioner/service provider to submit the plan’s Form 5500 or Form 5500-SF. If this e-signature option was used, the name of the practitioner/service provider whose electronic signature was applied to the Form 5500 or Form 5500-SF will appear on the image of the form in the signature area above the text “Signature of plan administrator.” The practitioner is not necessarily the plan administrator responsible for the filing.