2009 SB Filing problem - Relius

[AndyH]

Apparently (I've been asked to post this) Relius generates a validation error when a lookback month is entered in line 21b when the full yield curve has been used, and this validation error prevents filing.

Are there others out there who have experienced this and perhaps found a solution, or is everyone leaving that blank even though they may have used October 2008 rates?

[My 2 cents]

I just tested this. Yes, you get an error message. Sometimes you just can't get rid of all of the Relius error messages, and after reading through them (to make sure that you still agree with the entries), you just have to go ahead and print anyway.

I do agree that Relius ought to recognize that for 2009 (possibly also for 2008 if the plan year began late in the calendar year and the sponsor elected to use the October 2008 yield curve for, say, a plan year beginning in December 2008), lookbacks are certainly allowed for plans using the full yield curve. They should save this error message for the 2010 and later forms.

[AndyH]

Thanks for the feedback.

I am told that the Webclient ?? rejects filings that have such validation errors so that the form cannot be filed. Again, I am passing this along; I don't know exactly how this works - I have yet to file anything for 2009- but I am told that a local Relius rejection means it cannot be filed.

We have tried DOL and or EFAST to see what they say about 21B but have yet to get an informed response. We have not gone to Relius directly yet.

[FAPInJax]

Here is the government check:

Edit tests:

B-690SB Schedule SB, Line 21b should be blank when Line 21a (N/A, full yield curve used) is

checked.

[AndyH]

Thanks, but just to clarify, it is a government error? Clearly a lookback month is allowed for 2009. I'm just not sure how this works organizationally.

Are these edit checks available online somewhere?

[FAPInJax]

Well, my reaction is that the problem is with the government. The IRS approved a lookback for the full yield curve (note that it was not in the original law which may explain the EFAST problem).

I will see if the checks can be published. I believe it is a 1400 page document and is not really in English.

[AndyH]

Thanks for your help Frank.

[FAPInJax]

Unfortunately, the document is not something that can be published. It is coming from the entity that is doing EFAST and would only be released to software vendors (who are not permitted legally to release it).

I would suggest that ASPPA (through ACOPA) petition to have them release this document for public consumption.

[My 2 cents]

I would not consider it necessary to consult with any document concerning error checks.

2009 filings can use the full yield curve with a lookback. Of this there is no doubt. The government cannot reject a filing due to this, and all software being used to prepare 2009 Schedules SB that treats the combination as being an error should be modified to disable any such error check. The software providers could not need to clear such a change with the government.

If the government is rejecting such filings, it is an obvious system error that the government must fix, and quickly.