How does a small plan filer upload a .pdf attachment of financial statements?

[Peter Gulia]

A small plan's administrator files Form 5500 (not 5500-SF) and, although it does not engage a CPA to audit the plan's financial statements, prepares financial statements and wants to submit them as a part of the Form 5500 report.

How, mechanically, does a filer do this?

[Tom Poje]

with FT William, you could attach and select 'other attachment'. then you can name what the attachment is, does, etc.

[Kevin C]

ASC also allows an "Other attachment" option, although I would be concerned that the DOL might think it is an IQPA audit.

[Peter Gulia]

Tom Poje and Kevin C, thank you for your great help.

Am I right in guessing such an "other attachment" slot lets a user upload any .pdf?

Will the document submitted under this "other" slot be included within the Form 5500 report posted on EBSA's public-display website?

 

 

[Kevin C]

All attachments should be included with the filing on the DOL website, after they have been reviewed by the DOL.

[Bill Presson]

1 hour ago, Fiduciary Guidance Counsel said:

Tom Poje and Kevin C, thank you for your great help.

Am I right in guessing such an "other attachment" slot lets a user upload any .pdf?

Will the document submitted under this "other" slot be included within the Form 5500 report posted on EBSA's public-display website?

 

 

Yes. And I think it begs the question as to why the sponsor wants to do this. On the face, it makes no sense.

[Tom Poje]

if it is a pdf file there is no way for the IRS website what it contains so it should accept it. (or put another way, how the heck can the website know? if it was a word file it wouldn't take it because it is a wrong format, but other than that...)

I thought any and all attachments are viewable. I think, for example they warn you don't attach SSA because soc sec numbers would be visible

[BG5150]

Audited Financials are not shown immediately.

[RatherBeGolfing]

When you file with an attachment the DOL will not put up the filing until they have verified that the attachment does not contain certain personal information. 

[Peter Gulia]

Thanks for the further information.

In my experience, the Labor department is quick on checking the attachments for information that would identify a natural person.  I've seen a posted display including the attachments in as little as an hour after the submission.