Andy the Actuary Posted July 12, 2010 Posted July 12, 2010 In the case of a third party signing/submitting in behalf of Plan Sponsor, DOL EFAST2 Q&A indicates to attach first two pages of the 5500 with plan sponsor/plan administrator signatures. ASPPA No 22-10 on its sample filing authorization form says Page 1. Has the DOL changed it's position on what needs to be attached? 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.
pmacduff Posted July 12, 2010 Posted July 12, 2010 Although page 1 is the only signed page, I believe the EBSA has always held (since the change was made) that you have to attach both page 1 and page 2, in other words, a complete 5500. Perhaps just an error in the ASPPA release?
Andy the Actuary Posted July 12, 2010 Author Posted July 12, 2010 Have always advocated that more is better. I can recall visiting a confectionary as a kid. I asked the clerk how much was the striped candy in the bin. He said that I could have all I wanted for a penny. I said give me 2 cents worth. 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.
david rigby Posted July 12, 2010 Posted July 12, 2010 Have always advocated that more is better. Not too loud. Congress may think that more taxes is better. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
K2retire Posted July 13, 2010 Posted July 13, 2010 Have always advocated that more is better. Not too loud. Congress may think that more taxes is better. Haven't they always?
Bird Posted July 13, 2010 Posted July 13, 2010 I agree that both pages are needed. Read literally, the asap authorization only refers to p 1 or 2 going to the practitioner (who would then scan the other page and submit both...but that's kind of a weak defense!). Of course (?), the system doesn't know if you have attached both pages in the pdf, or a picture of your cat for that matter...I don't think anything would happen if you only attached the page with the signature. Ed Snyder
Andy the Actuary Posted July 13, 2010 Author Posted July 13, 2010 Our baby CAT named IRA 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 VEBAPLAN Posted July 14, 2010 Posted July 14, 2010 My dog is named VEBA not kidding He does promos on the Web. He is call the IRS dog. C'mon Lance, no advertising - Blinky
Belgarath Posted July 14, 2010 Posted July 14, 2010 While we don't have a dog, I always seem to be in the doghouse...
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