Unusual Processing Delay?

[Andy the Actuary]

I submitted the 5500-SF of the seaon on Friday, September 5 via EFAST2.

As of this posting, the IRS/DOL still have not released the attachments and the 5500-SF that can be viewed on the website is unsigned, undated. I do not recall this delay in prior years. Obviously, the review is to ensure the attachments do not contain profanity, pornography, political, racial, or other writing or images that do not pertain to the filing. Seems to me this can all be covered in the agreement.

(1) Is this delay unusual or now the norm?

(2) More important, when the IRS/DOL releases the form, will it show as signing date the form was submitted (i.e., September 5) or the IRS/DOL release date. If the later, then this could pose problems if submitting forms towards the October 15 deadline.

[Kevin C]

I haven't worried about how long it takes for the attachments to be shown on the DOL website, but it does seem to take a few days. From what I understand, they are still receiving a fairly large number of 8955-SSA filings and other items with participant information attached to the 5500's.

The AckID# listed for the filing on their website starts with the submission date, so you shouldn't have any problem showing when it was filed, even if you don't have a copy of the confirmation e-mail. I checked a couple of our recent large plan filings and they show a submission date that matches the AckID#. The signing date should come directly from the filing since it isn't necessarily the same as the filing date.

[Andy the Actuary]

Kevin, thank you!

[My 2 cents]

People are still attaching the 8895-SSA filings to the 5500 filing??? Are they paying any attention at all? It has only been a separate filing for something like 5 years (not to mention the improper handling of Class 1 information!). Have they also been properly filing them or have they repeatedly failed to submit the required filing? Tacking it onto the 5500 filing does not satisfy the 8895-SSA filing requirements.

That also reminds me of a pet peeve - actuarial valuation reports for defined benefit plans with comprehensive participant information (names, dates of birth and hire, salary information, benefit information, sometimes even Social Security Numbers) included as part of the report. The time is long gone when that would be considered an acceptable practice (which would have been around the time that stores stopped requiring Social Security Numbers to accept payment by check and RMVs stopped putting Social Security Numbers on driver's licenses).

[Guest Kristina K]

I went to EFAST to determine the best tactic for you to take. Here is what they say:

Filings that are searchable on the efast.dol.gov Form 5500/5500-SF Search page have already been processed, thus are not experiencing a "processing delay." Filers who need to check the processing status of a filing (and the date on which the filing was received) should do so using the software used to submit the filing, or logging in at www.efast.dol.gov and checking the Submissions page, or by calling the EFAST2 Contact Center toll-free number 866-463-3278 and using the automated status option. The "signed date" field on the Filing Search Page PDF is not used to determine when the filing was received.

When using the Form 5500/5500-SF Filing Search page on the EFAST2 website, the 'Signature of plan administrator' box on the Form 5500 and Form 5500-SF PDF facsimiles will be populated with text based on the presence and validity of the credentials used to sign the filing.

For filings that are signed using the E-Signature alternative for service providers, the 'Enter name of individual signing as plan administrator' box and the 'Date' box will be blank if the service provider signature credentials are present and valid unless the plan administrator signature credentials are also present and valid. The display of the 'Enter name of individual signing as plan administrator' and 'Date' boxes was changed as of January 1, 2014 with the new E-Signature signer role allowed on the 2013 Form Year.

The Department of Labor reviews all attachments for sensitive Personally Identifiable Information (PII) prior to disclosure on the efast.dol.gov Filing Search page that is available to the public. This reduces the possibility that personal information is accidentally displayed on the filing search page.

During the review process, the electronic form and schedule filing data is viewable when a PDF of the filing is generated. However, the attachments display a message indicating "Attachment(s) Under Review." If a PDF of the filing is generated, the attachments portion of the PDF will be replaced with a message that the attachments are being reviewed by the Department of Labor.

Once the Government review is completed, the "Attachment(s) Under Review" message is replaced with the actual attachment or a new message indicating that the attachment cannot be disclosed through the website.

Attachments are not publicly disclosed until the review has been completed (or after a maximum of 20 days have passed).

If the Department of Labor determines an attachment may contain sensitive personally identifiable information, the attachment will not be disclosed.

[Andy the Actuary]

Kristina, I thank you for your efforts.

This suggests all is hunky and dory!