How to file where Sponsor/Administrator are different and one is not available to sign?

[Guest R. Struve]

Plan administrator and plan sponsor are not the same entity or controlled by same group. EFAST won't take the 5500 filing without both the plan sponsor and plan administrator signing. However, plan sponsor is in process of dissolving and is refusing to sign 5500. Any ideas how to submit the filing without the plan sponsor's signature?

[Andy the Actuary]

Will plan sponsor authorize you to sign in his behalf?

[pmacduff]

That's strange...I know that EFAST won't take a filing without the "Plan Administrator or Practitioner" signature, but I've never had a problem with omitting the "Plan Sponsor" signature. That's how 99.9% of our clients sign.

In fact, it has been the other way around for me- where if the "Plan Administrator or Practitioner" signature is missing and the client signs as "Plan Sponsor", the filing rejects.

[chc93]

Well... at least in ftwilliam, a signer's name is associated with Plan Administrator and/or Plan Sponsor. If one name is associated with Plan Administrator only, and another name is associated with Plan Sponsor only, both have to sign. If one name is associated with Plan Administrator/Plan Sponsor, then only one name needs to sign... as Plan Administrator. I think the names/"titles" go along with the filing. In fact, if both PA and PS are different, I don't think ftwilliam will even submit to EFAST2 until both sign. At least that's how I understand how this works.

[BG5150]

Maybe impress upon the laggard what the penalties are for a late filing.