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Posted

I'm getting ready to do the DOL filing for the Top Hat Exemption and noticed that the DOL has a means for electronic filing.  But I can't tell if e-filing is now required or is still optional.  I have a mailing address that I used a few years back, but not sure if that's still the right address if we can still do a paper filing.

Posted

Not required yet, but highly encouraged and will be required in the future.  it's so easy there's no reason not to do it that way.

Top Hat Plan Statement

Plan administrators of "top hat" plans can use this web page to electronically file the statement described in section 2520.104-23 of the Department of Labor's regulations. Top hat plans are unfunded or insured pension plans for a select group of management or highly compensated employees. The Department recently published a proposed regulation that would make it mandatory to electronically file the statement. In the interim, plan administrators of top hat plans are encouraged to file plan statements using this electronic system. Plan administrators who use this electronic filing system will have satisfied the filing requirements under the current regulation. To go directly to the statement, click on the link "Proceed to File Your Top Hat Plan Statement" below.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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