"I'm trying to sign and submit a 5500-EZ on EFAST as a sole proprietor (both employer and plan administrator). The instructions on the DOL web site are terrible. On the 'add signers' page (as well as the users guide, I believe), it says:
Here are some things to consider when adding signers:
'• If the same person serves as both the plan sponsor and plan administrator, that person should check
both 'Plan Administrator' and 'Plan Sponsor' boxes.
• If one person serves in multiple roles, you need only add that person once as they will be able to sign for multiple roles at one time.'
However, on the signature page itself, it says:
'* Please select the role(s) for which you are signing. You may select all that apply. <checkbox> Plan Administrator <checkbox>
Employer <checkbox> Service Provider using E-signature alternative option (reference EFAST2 FAQ 33a) If the same person serves as both the plan employer and plan administrator, that person should check only one of the 'Plan Administrator' or 'Plan Employer' boxes. The IRS Code permits either the plan sponsor/employer or the administrator to sign the filing. However, any Form 5500 that is not
electronically signed by the plan administrator will be subject to rejection and civil penalties under Title I of ERISA.'
I bolded the relevant sentences. The site literally contradicts itself. The page for adding signers says 'If the same person serves as both the plan sponsor and plan administrator, that person should check both "Plan Administrator" and "Plan Sponsor" boxes.' The actual
signing page says 'If the same person serves as both the plan employer and plan administrator, that person should check only one of the "Plan Administrator" or "Plan Employer" boxes.'
To validly sign the 5500-EZ, do I check both boxes, as I am both employer and plan administrator (and sponsor), or do I only check the 'plan administrator' box?"