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Posted

Hi

When filing the 5500 forms on behalf of a client with the esigner authorization signed by the client, does the 5500 form need to be a wet signature? I have attended many podiums where it was ok thru DocuSign or something similar.

Someone I am dealing with is insisting on being wet which I do not think it is correct?

Also, looking at a possible takeover where the actuary signature on SB is electronic. I thought SB's has to be wet signatures.

Thanks for your comments.

Posted

Look at the instructions for the 5500 page 6 or 5500-SF page 7 in the section titled Authorized Service Provider Signatures.

It says among other things that:

"(3) that, in addition to any other required schedules or attachments, the electronic filing includes a true and correct PDF copy of the completed Form 5500-SF (without schedules or attachments) return/report bearing the manual signature of the plan administrator or employer/plan sponsor, as applicable, under penalty of perjury;

(4) that the service provider advised the plan administrator or employer/plan sponsor, as applicable, that by selecting this electronic signature option, the image of the plan administrator’s or employer/plan sponsor’s manual signature will be included with the rest of the return/report posted by the Department of Labor on the Internet for public disclosure;"

The instructions for the actuary's signature on the Schedule SB are

"The actuary must provide the completed and signed Schedule SB to the plan administrator to be retained with the plan records and included (in accordance with these instructions) with the Form 5500 or Form 5500-SF that is submitted under EFAST2. The plan’s actuary is permitted to sign the Schedule SB on page one using the actuary’s signature or by inserting the actuary’s typed name in the signature line followed by the actuary’s handwritten initials."

 

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