DFVCP Questions

Need to file 5500s back to 2002 for a small plan.  Have a few questions.

Will all the filings appear on EFAST2 for public viewing?

If so, how should the Schedule P be handled since it requires a signature and will be attached as a PDF?  Should it be treated as an SB an only have the fiduciary's initials?

Is the concern that the signature will be viewable?
Any 5500s filed by a third party vendor (instead of with a PIN directly by the signer) has an attachment with the signature on it. So there are lots of 5500s out there on efast with signatures already. 

Many vendors have the signers use their PIN for direct filing ( or semi-direct filing through the preparation software), but not all do. Some plan sponsors find it easier to wet sign, and authorize the service provider to e-file on their behalf.  When done that way, a copy of the wet signed Form 5500 is usually visible. 

I don't know that will make your sponsor feel, better, but it might.  Or they just might think the ones that don't direct file with a PIN are taking an unnecessary risk. 

I believe that prior year filings are not published on the website.

54 minutes ago, Kristina said:

I believe that prior year filings are not published on the website.

I can assure you that filings are available on efast for public viewing, even if filed as part of DFVCP. We have a number of clients that have used DFVCP and their late filings are viewable the same as if they had been filed timely. If there are other reasons why it wouldn't be available (one-participant plan etc, ) those limitations would still apply. 

But if you have a one participant plan, you wouldn't be correcting with DFVCP anyhow. You'd use the special program for those kinds of plans. 

Now, I can't say if they would all be available back to 2002... for most plans the filings on efast only go back a few years. I don't know if they are archived based on the plan year end, or on the filing date. If based on plan year end, I would think the very early years (2002 to maybe 2013) wouldn't be on efast. But if done based on filing date (which is what I think is more likely) then if all filed this year, they would all be available for download. 

Respectfully, I’m not sure why you’re going back that far to begin with.

Typically, we might go back ten years but no more,

I’ve had discussions with both regulators about this at a high level.

The Form 5500/5500-SF filing search says this...

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This search tool retrieves Form 5500/5500-SF forms, schedules, and attachments filed since January 1, 2010. It allows you to search for multiple filings and view one complete filing at a time.

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(emphasis mine)

I recall at one time reading that 5 years would be available for viewing.   But it does say *filed since*.  So even older Form 5500's filing now through DVFCP will probably be viewable.