Terminated Plan - 5500 Rejected by DOL in Error

[BeanCounterBlues]

I recently had a client e file the final 5500 SF for a terminated 401k plan. This was a 2011 short plan year filing (on 2011 forms).

Part I, line B "the final report..." was properly checked. EOY partic / assets = zero. Part VII Plan Terminations questions properly completed.

The DOL rejected the filing on the basis that "criteria for termination have not been met" error code P 215 SF. The notice of rejection advisement was provided to me, by the software vendor.

I called the EFAST toll free help desk and confirmed that the filing status is "filing received" which I understand to be the highest level of acceptance in the EFAST II system. I checked the public disclosure website and the filing looks fine as well.

I contacted my software vendor and they informed me they have had this happen several times. EG a terminated filing that appears in all respects proper, is notified to the software vendor as "rejected." But - the DOL web posting and "filing received" status is what appears to be in the DOL's systems.

The software vendor has recommended not taking any further action and to just assume the rejection notification by DOL to software vendor was an unexplainable error.

I hesitantly-tend to agree, because the public disclosure website and "filing received" status seem to indicate everything is fine. However - I am a little leery of the software vendor's recommendation to "do nothing."

I realize checking the amended box and having the client re-e-file is probably not a good thing to do (eg amend it and see if the DOL actually will issue an acceptance to the software vendor).

Has anyone else been faced w/ this and if so what action did you take (if you are willing to share). Thank you for any thoughts.

[NJ Mike]

I had the same problem but I had left Item 7a on Form 5500-SF blank. When I redid putting in "0" for that Item, my problem went away.

Mike

[BeanCounterBlues]

Thanks Mike - I'll try that.

[Tom Poje]

or possibly number of participants was left blank instead of zero.

I forget what the reason was, but I had a similar message - but that was before submitting, running an edit check on FT William.

and then it was a matter of figuring which item it was that wasn't checked.

good luck, my guess it is probably something "obvious" that was missed, at least my response was more like "Well Duh. That sure was dumb of me!"