Pre-approved plan opinion letter serial number

[Belgarath]

With the new 2023 forms, this number will be required. The IRS has informally indicated that this will be available as part of the 5500 data sets. So, anyone can look up the opinion letter serial number for a given TPA, and essentially obtain your client list for 5500 filings under each pre-approved plan you sponsor.

Is the ARA raising any hell on this? Seems pretty serious to me! 

[Paul I]

The issue has been out there.  I personally raised it when I did the 5500 presentation in May for the ASPPA Spring National.  There was no reaction from the attendees.  The issue also was highlighted this week in ERISApedia's 5500 webinars.  Other than that, I have not heard of anyone expressing a concern about it.

The draft form was available for comment and apparently there were no objections.  The form was released in June to 5500 software developers and the final official release will occur likely this December. 

I understand that the plan Opinion Letter numbers will be a data element included in the downloadable data files from EFAST2.  The IRS already publishes a list of plans they have approved for each TPA.  Together, that should make it almost a trivial exercise to prepare a national TPA client list by type of plan. 

 

[thepensionmaven]

This is nothing new.  There have been several 5500s in the past that have asked for the IRS Approval Letter.

[RatherBeGolfing]

On 7/18/2023 at 1:03 PM, thepensionmaven said:

This is nothing new.  There have been several 5500s in the past that have asked for the IRS Approval Letter.

Data mining is much more accessible now though.  I could download the IRS list of approval letters and do a data dump of the 2023 5500 with a couple of clicks and have a table of all plans with 2023 returns and who their document provider is.

If I was still with a small TPA firm, that would concern me.