Plan Administrator EIN

[Marty]

The IRS is not able to answer this question for me.  If a Plan Administrator is responsible for several ERISA plans, do they need to apply for a Plan Administrator EIN (thru SS-4) for each plan? Or does the Plan Administrator just receive a single EIN which is then used for all plans they administer?

Thank  you!

Marty Wayne

MartyWayne@ColonialFundingLLC.net

Direct: 847-971-1057

[RatherBeGolfing]

I think you are referring to a plan EIN rather than an EIN for the plan admin.  You would use this to establish accounts, prepare Form 1099/945, etc.  These EINs are plan specific.  Otherwise, you wouldn't know which plan an account was established for, what plan issued a distribution, and so on.

[Marty]

Thanks, but I actually was referring to the Plan Administrator, not the Plan itself. The Plan Administer also applies for its EIN on the SS-4 (type of entity on Line 9a would be "Plan administrator"). I am not clear if a Plan Administrator needs an EIN for each plan that for which they are the Plan Administrator. Or if the Plan Administrator only obtains one EIN and uses it for each of the plans it administers. The reason I question it is that when filing the SS-4 online and selecting "Plan administrator", it does not even ask for the name of the Plan, just the name of the Plan Administrator. The IRS was unable to provide assistance, and our CPA was unsure.

[Paul I]

IRS Publication 1635 does a decent job explaining the use of EINs. See https://www.irs.gov/pub/irs-pdf/p1635.pdf

Plans do not get EINs.  A Plan Sponsor gets an EIN.  Each plan that the Plan Sponsor sets up gets a unique Plan Number (e.g., 001, 002,... 501, 502...)  The pairing of the Plan Sponsor's EIN and PN creates a unique identifier for each plan.

If the Plan Sponsor is designated as the Plan Administrator, there is no need for the Plan Sponsor to get another EIN for its role as Plan Administrator.  If someone or some group separate and apart of from the Plan Sponsor is designated in the Plan Administrator, then that someone or group should get its own EIN.  This may be an individual or a committee or a professional services firm.  This EIN will not be an identifier of any of the plans the Plan Administrator serves, and the Plan Administrator does not have to get a separate EIN for each plan they serve. One way to look at it is the Plan Administrator's EIN is like a social security number for the Plan Administrator - it is a unique identifier for Plan Administrator and not the plans the Plan Administrator serves.

[Marty]

Much appreciated.  Thank you!

 

[Bill Presson]

17 hours ago, Paul I said:

Plans do not get EINs.  A Plan Sponsor gets an EIN.  Each plan that the Plan Sponsor sets up gets a unique Plan Number (e.g., 001, 002,... 501, 502...)  The pairing of the Plan Sponsor's EIN and PN creates a unique identifier for each plan.

 

For plans that aren't at recordkeepers, the trust for that plan quite often DOES get an EIN to use to identify assets and to use when paying people out for tax deposits and 1099 reporting.

With independent paying entities providing distribution services, it's becoming less common but we still use it pretty frequently.

[Gilmore]

1 hour ago, Bill Presson said:

For plans that aren't at recordkeepers, the trust for that plan quite often DOES get an EIN to use to identify assets and to use when paying people out for tax deposits and 1099 reporting.

Employer would get an EIN; Trust would get a TIN.  Is that what Paul was referring to?

[Gilmore]

4 minutes ago, Gilmore said:

Employer would get an EIN; Trust would get a TIN.  Is that what Paul was referring to?

Nope, that was wrong.  Sorry about that.  Should have left for Thanksgiving break.