Andy the Actuary Posted July 11, 2010 Posted July 11, 2010 A pdf of an SB that is signed or initialed must also be embedded in the xml transmitted to IFILE (at least that's how I'm doing it). Must the pdf of the SB include all of the attachments (plan provisions, assumptions, age/service array, etc.), or do we simply embed the first 3 pages of the signed/initialed SB? The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
chc93 Posted July 12, 2010 Posted July 12, 2010 According to ASPPA, the IRS said that only the first 3 pages (but not the attachments) must be in the separate PDF file. Also, the IRS said that the actuary's typed name does not have to be on the signature line (only the initials are required) since the actuary's name is already provided on the Schedule SB/MB, and it was not intended that the actuary's name be typed twice on the form.
Andy the Actuary Posted July 12, 2010 Author Posted July 12, 2010 According to ASPPA, the IRS said that only the first 3 pages (but not the attachments) must be in the separate PDF file. Also, the IRS said that the actuary's typed name does not have to be on the signature line (only the initials are required) since the actuary's name is already provided on the Schedule SB/MB, and it was not intended that the actuary's name be typed twice on the form. Actually, and here is where I got confused, ASPPA said, "The entire Schedule SB or MB (but not the attachments) must be a separate attachment labeled "SB (MB) Actuary Signature." You have interpreted this likely correctly as ""The entire Schedule (but not the attachments) SB or MB must be a separate attachment labeled "SB (MB) Actuary Signature." The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
Guest Mongee Posted July 13, 2010 Posted July 13, 2010 A pdf of an SB that is signed or initialed must also be embedded in the xml transmitted to IFILE (at least that's how I'm doing it). Must the pdf of the SB include all of the attachments (plan provisions, assumptions, age/service array, etc.), or do we simply embed the first 3 pages of the signed/initialed SB? Where did you hear that the IRS said you don't need to type the name? Is there an "official" or linkable documentation for this? (The typed name is a pain, but following the instructions, it would seem required.)
Mike Preston Posted July 13, 2010 Posted July 13, 2010 ASPPA has published it more than once and I think, if memory serves, that an Employee Plan News article echoed it.
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