Filing Authorizations for when TPA files the 5500

We have out clients complete a "filing authorization" form every year when we, as TPA, are filing the 5500 on their behalf.

Do we NEED to have one completed every year?  Can we do just one that says Sponsor A authorizes TPA to file on behalf of Sponsor for all years until authorization is rescinded?

I was also thinking that the authorization would be rescinded if the signer of the 5500 changes for any year.

Is there a rule that you have to get one each year?  Link?

We get one every year; I don't remember the language but I don't see it as permitting a permanent authorization.  (How could one authorize the filing of a 2019 5500 in 2017 or whenever?  I think it potentially creates liability on our end - basically we are filing something with no evidence of it being reviewed or approved by the plan sponsor.)  I can tell you that Larry Starr thinks otherwise.

1 hour ago, Bird said:

We get one every year; I don't remember the language but I don't see it as permitting a permanent authorization.  (How could one authorize the filing of a 2019 5500 in 2017 or whenever?  I think it potentially creates liability on our end - basically we are filing something with no evidence of it being reviewed or approved by the plan sponsor.)  I can tell you that Larry Starr thinks otherwise.

DOL said back in 09(?) that you need to get a new one signed each year, and I believe that is still their position.  We get one every year.

I don't see a liability or a problem with an evergreen authorization though.  You still need the signed Form 5500 from the client, so you can assume that they reviewed and approved when they signed.

https://www.asppa-net.org/sites/asppa.org/files/PDFs/GAC/ASAPs/11-13.pdf

1 hour ago, RatherBeGolfing said:

You still need the signed Form 5500 from the client, so you can assume that they reviewed and approved when they signed.

Good point, I wasn't thinking.  And thanks Belgarath for the cite.  I may have been on the committee at the time...