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Posted

We were considering the delivery of the restated PPA document by electronic delivery as opposed to a bound paper copy.

One concern is that no one will have an original signature on the documents.

With so many clients going paperless, is it still required that the client maintain a copy of the plan document with original signatures?

Will this "pass" in an audit?

Posted

They can print the signature pages, sign them, and scan back in.

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

Posted

"They can print the signature pages, sign them, and scan back in".

Correct, this is our intention. As a result, they would end up with a scanned copy...not an original.

"I don't think "original" signatures are necessary. A full scanned copy of the document should suffice. Every document I ever sent to the IRS or DOL was a copy. Good Luck!"

And you are comfortable with the fact that if an IRS agent that would show up at the plan sponsor's office for a random audit would accept a scanned copy of the document rather than a fully executed document with original signatures?

Thank you both for responding to this issue. I appreciate it.

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