RGF validation

[pmacduff]

here is a strange one:

Client had given us the wrong EIN number back in 2007 (new client & plan). I discovered this when I was trying to validate the 2009 5500 in RGF this year, it would not validate the number. I verifed with the client that the number was in fact incorrect and they gave me the correct number. 5500 and schedules will validate with the correct number.

Now...when I fill in form 5500, Part II, 4a, 4b & 4c (so that the EBSA and IRS will know that we updated the EIN number), the form will once again not validate. I even tried importing it to the EBSA website anyway but it won't accept the form for import.

When I spoke with Relius support the first time, they told me that the system isn't "smart" enough to know that the number was invalid. No one is sure why the number wouldn't validate before. I have a new incident in to try and fix this newest problem but since the wait is long I thought I'd see if anyone else has had a similar problem and/or any fixes??

ok - addendum to this...I found out that "28" is not an acceptable start for an EIN. You can't even enter it. This is why it won't validate.

The problem is that the 2008 form WAS filed with the EIN beginning with "28", so I've emailed the EFAST help area and hopefully will get an answer soon.

I'll update this post when I hear back....

[pmacduff]

Heard from the EBSA this morning.

Since "28" contains invalid characters in the eyes of the EBSA, there is no way to put this information on the 5500 form and have it accepted.

I was advised to use an "Other Attachment" *pdf file and put the information/an explanation in there so that's what I did.

Whew!

[Tom Poje]

this should be fun.

the IRS will look for a 5500 for the EIN begining with 28 even though it is impossible.

they will send you a letter with a penalty because you haven't filed and you are late.

you know they won't be able to read the attachment to see that the EIN was changed - in fact they will probably wonder why you never filed on the plan before since it has assets, but they have no record of the filing under the new number.

(I only say this because awhile back we received a leeter asking why we didn't file for a plan, and this was one where the EIN was changed, and properly noted in item 4, yet they didn't recognize it was changed)

[pmacduff]

Yeah Tom - I agree & I have prepared the client. Explained that they may get a letter claiming the EBSA did not receive a final return on the "28" and as you mentioned and also a letter asking why the 2009 "26" return was not marked as a "first return filed"!

I guess we'll cross those bridges when we come to them. It will be so much fun!

I'm just curious as to why there is a whole set of numbers that the EBSA considers to be invalid characters for the 1st 2 digits of the EIN numbers.

I think that it is perhaps because they know for some reason that those numbers were never assigned?

They should at least allow the numbers to validate in question #4 in case anyone else has the situation that I did!