Is it late?

[MarZDoates]

Has anyone had this happen:

Form 5500 EZ efile confirmation says:

Date Type of Activity

10/15/14 Transmitted to FD (I have a submission number)

10/16/14 Accepted by FD on 10/16/14

If so, was the filing consdered late?

(Calendar year plan on extension.)

Thank you.

[Lou S.]

Do you mean 1 person 5500-SF?

I would say if you have the transmission log showing 10/15 filing you should be fine even if IRS/DOL sends a late notice; a simple letter will a copy of the 10/15 transmission should end any further inquiries.

[MarZDoates]

I meant to say 5500-SF. Sorry! Brain not functioning correctly today. Thanks for the reply.

[chc93]

Supposedly the filing deadline is 12 midnight in the time zone of the plan sponsor.

Just for info, I had one plan that was filed on Oct 6 at 11 PM local time in our time zone (got an email confirmation from ftwilliam.com). We are 6 hours behind EST. The DOL/EFAST system recorded the filing as Oct 7. Since then, we made sure that our plans electronically filed by 6 PM our time on Oct 15 (which would be 12 midnight on Oct 15 EST).

[Kevin C]

From the DOL website:

Q35a: Exactly what time is my filing due, and what time zone does that reflect?

Timely returns/reports must be received by EFAST2 by midnight in the plan administrator’s time zone. The plan administrator’s time zone is determined by the plan administrator’s address specified on Line 3a of the Form 5500 or Form 5500-SF.

In an instance where the filer attempts to submit a return/report on time and it is not successfully received by EFAST2 prior to the deadline, the filer should print the unsuccessful submission notice. The unsuccessful submission notice should be included with the resubmitted return/report and tagged as an “other attachment.” Based upon the facts and circumstances surrounding the original unprocessable submission and the subsequent resubmission, penalties may still be assessed from the original due date if the subsequent resubmission is received by EFAST2 after the deadline.

http://www.dol.gov/ebsa/faqs/faq-EFAST2.html

I looked at some of our filings. The "Submit Date" on the DOL website uses Eastern Standard time. The AckID shows the date and time using the time zone of the filer.

[chc93]

I looked back at the AckID for the filing I mentioned above. the AckID shows 20141007... Oct 7. The time zone of the filer was Oct 6. Anyway... maybe 11PM local time zone was too close for comfort in this case.

(edit) Here's ftwilliam.com email...

******************

From: ftwilliam.com <5500StatusUpdate@ftwilliam.com>
To: <me>
Sent: Monday, October 6, 2014 10:59 PM
Subject: 5500 Status Update

Dear <ME>,

The status for the 2013 filing for:
<Doctor>, M.D., Inc. Profit Sharing Plan (001)

has been updated to 'Accepted' with AckID '20141007035935P040012875455001'

******************

Note the date the email from ftwilliam.com was received was Oct 6 local. AckID shows Oct 7.