5500 Sch H plus IQPA & financial stmt

[doombuggy]

This client is a fiscal year plan that ended 8/31/2010, so this is their 1st EFAST2 filing.

They are my only large plan, so I have not filed any 5500s with an attachment on EFAST2 as of yet. And yes, it is due on Wed 6/15....CPA just sent me the final Sch H and a draft of the financial stmt w/IQPA. They are waiting for the client to sign off on it. Note the draft they sent to me is not signed by the CPA (she usually signs her company name on the Independent Auditor's Report page). When this was sent in paper form, both the auditor's report page and the financial statements were bound up together. The draft copy that was sent over this am was the same - both pieces together is the same PDF file.

Is this ok?

What is the attachment supposed to be called - "FinancialStatements?"

Thanks for your help! I need to publish this on Monday for the 2 trustees to sign so I can transmit it by Wednesday!

[ESOP Guy]

You need the final audit report, sorry. I have 3 due next Wed and I don’t have the final reports yet either.

Oh, the attachment is more likely called the Auditor’s Opinion.

[doombuggy]

It's a 15 page PDF file that they just sent me a finalized version of. It's called "Financial Statements & Supplemental Schedule with Independent Auditor's Report."

I know the attachedments for DB plans are suppoed to have specific titles when sending them via EFAST2, and the only one I can find that pertains to Sch H is "FinancialStatements."

Oh, on pg 3 of H, opinion is "disclaimer."

[Guest Dell]

First, that is the expected way to receive the aditors report and financials, in a single PDF file. Since the opinion is a disclaimer, you should read the opinion to determine whether they performed a "limited scope" audit in accordance w/ the regs. If not, the disclaimer would likely mean rejection of the filing. If it's a limited scope, you will have to answer the question on Sch H properly.

You are correct that there are several different attachments to the 5500, all related to that final audit report. My view is that it is easier to attach the entire report to the 5500 item for the auditors opinion, and then attach a simple note to all the other required attachment tags saying the item is included in the opinion attachment. In other words, the financial statements and notes, sch of reportable transactions, sch of assets held at end of year, etc. all have to be linked to separate spots onthe 5500. Since they are all in the single file sent by the auditor, it is acceptable to just link the entire thing to the opinion tag and then a single page explanation to each other 5500 tag saying the item is included with the opinion attachment. This is easier than splitting the single PDF file into several different attachments.

[ESOP Guy]

The attached is from the IFILE system instructions. The vendor software we use (Pension Reporter by Datair mirrors this) you will see the first thing listed is accountant’s opinion. Later there is a financial statement.

It is my opinion that “accountant’s opinion” is the better place to put the attachment of the auditor’s opinion.

EFAST2_IFILE_User_Guide_1_.pdf

[Guest Dell]

"acountant's opinion" is the auditors opinion, and yes, that is the spot to attach everything in the report as long as you attach simple explanations to all other required locations. Otherwise you have to split the file and attach all the parts separately, which, at least to me is not worth the time since they allow you to link them all in one place.

[doombuggy]

I think my confusion was that I thought I was required to include 5 attachments, but I really only have 2 attachments (financialstatements & schassetsheld). while I did remove the schedule of assets from the original PDF, it is also left in there, as it is just one page. should be ok. My other concern was the name of the attachements. I named them in accordance to the EFAST2 guide.

[Guest Dell]

Looks to me like you need at least 3 attachments: opinion, financial statements w/ notes, and the sch of assets held. Sounds like there is no sch of reportable transactions in your case?. You can split the 3 items and link separately as you seem to be leaning, or link all together in the opinion tag, with simple explanations referring to that location linked to the other two locations, as described in the EBSA materials.

[doombuggy]

I just got into a screaming match with one of the EFAST2 people. Their stupid website claims that in Appendix E of their EFAST2 Guide to Filers & Service Providers lists the Types of Other Attachments. Appendix E has something to do with PINs. The list from a year ago (doc version id 4.2/032310F) has a list, with 5 items on it for Sch H. "Accountant's Opinion" is not one of them. While I attached the opinion in "Financial Statements" as the CPA did not split out the PDF file, and sent a sesond seperate attachment called "schAssetsHeld" which was the last page of other attachment, I now have to resend the entire thing as amended, because it's looking for a third attachment I didn't know has to be seperated! I am so :angry:

[Guest Dell]

I'm not following you. I told you you have at least 3 attachments, either all items combined with the opinion, and then 2 separate attachments referencing the first location; or 3 separate attachments of the actual documents. On the EFAST website, when looking at your filing, there is a button labeled attachments. The very first item is "accountants opinion". Each of the other attachments is also included in the list. Simply hit the "attachments" button, select the appropriate attachment from the list and browse out to where you have the PDF file and upload. Repeat for all 3 attachments in your case. The attachments are all labeled via the selection on the website, I don't think the file name you give it when saving on your harddrive makes any difference at all.

You have to use the separate links for each required attachment, whether you are attaching the required sch or just a reference to another location where you uploaded all the attachments together.

[doombuggy]

No, you are not following me. I use Datair, we do NOT use IFILE. The instuctions/list that I mention in my post above was given to me by my boss, who had processed Hs thru EFAST2 before. since this plan has a fiscal year, this was our first EFAST2 submission. My boss had 2 attachments to each of the 2009 plans he had with sch h and neither one had an attachment called "accountant's opinion."

Needless to say I had to post an amended return with the exact same stuff as the original; I followed Datair's instrcutions and copied the CPA's pdf into another PDF and called it "accountant's opinion." The DOL needs to do a better job with their guide book (which I proceeded to complain about to them in an email).

I hope no one else has the problems I had with this.

[Guest Dell]

I use Relius. "Accountant's Opinion" is one of the attachments available in the software. As you know, it's also included for direct import on IFile.

The Efast Guide you referenced does show the Accountant's Opinion as an allowed unstructured attachment, which is what you ended up doing anyway.

I'm just curious about other software out there. I guess Datair does not have any provision to attach the Accountant's Opinion to the filing? Is that true for other software?

[pmacduff]

FWIW - we use ft william and we too can attach the "accountant's opinion" as an attachment.