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Q2: How can I file my timely plan year 2008 annual return/report if it is due
after January 1, 2010?
Q3: Short plan year 2009 annual returns/reports (Form 5500 or Form 5500-SF)
may be due before EFAST2 can receive them in January 2010. How do I file these? Q4: How can I submit a delinquent or amended Form 5500 return/report for a Title I plan for years prior to 2009 once the EFAST2 system is available? To submit a delinquent or amended Form 5500 return/report electronically through EFAST2 for plan years prior to 2009, you must submit the filing using current filing year Form 5500, schedules, and instructions except as provided below. The current filing year forms take the place of the Form 5500 pages that would have been included in the prior year's filings. The electronic filing on the current filing year Form 5500, however, must indicate, in the appropriate space at the beginning of the Form 5500, the plan year for which the annual return/report is being filed. Exceptions to requirement to use current filing year schedules and instructions: Filers using EFAST2 must use the following correct-year schedules (that is, the plan year for which the annual return/report relates) completed in accordance with the related correct-year instructions:
For example, if you are filing a delinquent 2007 Form 5500 return/report for a defined benefit pension plan, you must include the 2007 Schedule B, Schedule R and all required attachments for these schedules. Attach them as pdf images to the current filing year Form 5500 (2009 or 2010 forms can be used as current filing year forms as of 1/1/2010), tagging them as "other attachments." Also, you have the option of using either the current filing year or the correct-year (2007 in this example) Schedule C. Since the Schedule E would not apply to a defined benefit plan, and the Schedule P and Schedule T did not apply for 2007 plan year filings, all other required schedules and attachments should be completed using current filing year forms and instructions. The entire filing should then be filed electronically in accordance with EFAST2 electronic filing requirements. To obtain correct-year schedules and related instructions, go to this listing and print the schedules and instructions of the form year that corresponds to the plan year for which you are filing. IMPORTANT: Do not attach any Schedule SSA to any filing with EFAST2. Rather, submit the most current year Form 8955-SSA to the IRS (along with all required attachments). See www.irs.gov/ep for additional information. IMPORTANT: Do not send any penalty payments associated with a delinquent filing to EFAST2. Penalty payments to the IRS or made under the Department's Delinquent Filer Voluntary Compliance (DFVC) Program must be submitted separately in accordance with the applicable requirement. Q5: What is IFILE? Q6: Do I have to use IFILE? Q7: How do I know what third party software is approved? Q8: What are the benefits of using EFAST2-approved third party software
instead of IFILE? IFILE can not be used to transmit batches of filings; it can only be used to transmit single filings. Many third party preparers benefit from transmitting batches of filings. Some EFAST2-approved third party software may support transmission of batches of filings. IFILE does not help you prepare an annual return/report. Some EFAST2-approved third party software may integrate with your systems to automatically populate some of the information required. IFILE does not contain filing assistance or integrated instructions. Some EFAST2-approved third party software may provide such value-added support. IFILE does not allow more than one individual to edit a filing without exporting, downloading, importing, etc. (see question 20 and 30); whereas, some EFAST2-approved third party software may provide such file sharing functionality. With file sharing as part of the software, different people can work on a single filing in a coordinated and streamlined manner. Q9: I currently use EFAST-approved software to prepare my Form 5500 and then
print and mail the annual return/report to EFAST. What will I need to do
differently for my plan year 2009 annual return/report? Instead of printing and mailing the annual return/report to EFAST, the plan administrator must electronically sign it and then the electronically signed annual return/report must be submitted over the Internet to EFAST2. Your EFAST2-approved third party software will transmit the filing to the EFAST2 system and subsequently provide you with your filing status. Registering For EFAST2 Credentials Q10: When can I register for EFAST2 electronic credentials to sign a Form 5500
or Form 5500-SF? Q11: When I register for electronic credentials through the EFAST2
web site,
what are the different user types and what type(s) of user should I select? Filing Author: Filing Authors can complete Form 5500/5500-SF and the accompanying schedules, submit the filing, and check filing status. Filing Authors cannot sign filings unless they also have the “Filing Signer” role. If you are using EFAST2-approved third party software to author your filing rather than IFILE, you do not need to check this box. Filing Signer: Filing Signers can sign Form 5500/5500-SF filings. Signers must ensure that the filing information is correct prior to its submission. The signer’s signature indicates that to the best of the signer's knowledge and belief the filing is true, correct, and complete. Signers include Plan Administrators, Employers/Plan Sponsors, and Direct Filing Entities. No other filing-related work may be done by the Filing Signer if this is the only user type selected. Further, for purposes of Title I of ERISA, the plan administrator (either as the Filing Signer or, if a non-individual entity, on whose behalf an individual authorized to sign on behalf of the plan administrator has signed as a Filing Signer) remains legally responsible for the timeliness of the submission of the Form 5500/5500-SF by a Transmitter. Schedule Author: Schedule Authors can complete one or more of the schedules that accompany Form 5500/5500-SF. Schedules created by a Schedule Author are not associated with a filing. For a schedule created by a Schedule Author to be used in a filing, the schedule must be exported. This exported file will then be imported by the Filing Author to the correct filing. Schedule Authors cannot initiate, sign, or submit a filing. If the Filing Author is using EFAST2-approved third party software to author your filing rather than IFILE, then you do not need to check this box. Transmitter: Transmitters can transmit Form 5500/5500-SF filings to the EFAST2 system for processing on behalf of others. Transmitters are responsible for the security of all filing information prior to and during its transmission. A Transmitter can be a company, trade, business, or individual. Third-Party Software Developer: Third-Party Software Developers make Form 5500 filing preparation or transmission software for use in the EFAST2 system. They submit test cases using their software to the Participant Acceptance Testing System (PATS) Team. The PATS Certification Team will then review their submissions and provide feedback or approve and certify the software. A Third-Party Software Developer can be a company, trade, business, or individual. Q12: If I am completing a Form 5500 or Form 5500-SF using an EFAST2-approved
third party software program, will I need to register for EFAST2 electronic
credentials? Q13: When registering for EFAST2 credentials, what’s the difference between
a Filing Author and a Transmitter? Q14: What do I need to do to serve as a third party software provider under
EFAST2? If you are developing software that will be used to prepare annual return/report filings, you will need to seek certification for filing preparation software. The certification for filing preparation software checks that the XML files designed to populate the annual return/report and schedules are correctly assembled and formatted. If you are developing software that will be used to transmit filings, you will need to seek certification for filing transmission software. The certification for filing transmission software checks that the web requests using the third party software can be correctly sent by transmitters to EFAST2 and received from EFAST2 by the transmitter. Initial third party software developer specifications have been provided to prospective developers. If you have not received these and are interested in being an EFAST2-approved third party software developer, please call 1.866.GO-EFAST. Q15: I already have a PIN and ID for electronic filing in EFAST. Can I use
that for submitting my filing electronically in EFAST2? Q16: How can I update my email address or other contact information after I’ve
registered? Completing An Annual Return/Report (Form 5500 or Form 5500-SF) Q17: I am filing a Form 5500-SF for a plan covered by Title I of ERISA and the
plan invested in a direct filing entity. I don’t see a way to complete a
Schedule D for a Form 5500-SF. Do I have to attach a Schedule D? If you are filing the Form 5500, you must submit all required schedules and attachments, including the Schedule D, if applicable. Q18: I don’t see a way to complete a Schedule SSA in EFAST2. How do I file
my SSA information with the Government? If you include a social security number on your annual return/report (such as appears on the old Schedule SSA) or in any of the attachments (including PDF or other forms of attachments), your filing may be rejected. Because your filing, including any attachments, will be posted on the Internet, it must not contain any Schedule SSA information or social security numbers. For more information on the form that replaces the Schedule SSA, please contact the IRS (www.irs.gov). Q19: How can I see what my annual return/report will look like before it is
filed? Q20: Can I show my annual return/report to other people for review before I
submit it to the Government? Q21: Is there a way I can check to see if there are errors in my filing before
I submit it? After a filing is submitted to EFAST2, the Government may perform additional checks of the annual return/report, and your filing may be rejected based on these additional checks. Q22: Can a draft Form 5500 be "submitted" for viewing online and
reviewing? Q23: If the answer to a question seeking an amount is none, or zero, should I
fill the numeric fields with zero or leave it blank? If you leave an item blank that should be zero and then validate your annual return/report for errors, you will be notified that item must be completed. Conversely, if you enter zero in an item that should have been blank and then validate your annual return/report for errors, you may receive different error messages. Consult the Form 5500 or 5500-SF instructions for guidance specific to each question on the forms. Q24: How do I attach the report of the independent qualified public accountant
(IQPA report)? Q25: Will the EFAST2 system still receive my filing if I do not attach the
IQPA report with my Form 5500 annual return/report when it is required? Q26: If I am filing for an extension of time based on a request for an
extension submitted on Form 5558 with the Internal Revenue Service, do I need to
attach a copy of the Form 5558 to my Form 5500 or Form 5500-SF? Q27: What file format do I need to use for attachments to my filing to make
sure they get transmitted to and received by EFAST2? Q28: How do I turn an attachment into a PDF file? Q29: Can I turn a paper document into a PDF file? When creating a PDF file by scanning a paper document, you need to be careful that the resulting file size is not too large. There is a limitation on the size of submissions sent to EFAST2. Scanning your document at 300x300 resolution and using True Gray, Grayscale, or Black and White color depth can help to minimize the resulting file size of the PDF. If you are scanning multiple pages and your scanner does not have a document feeder, you will need to scan each page and then combine them into one PDF file for each attachment type. Check that your pages appear in the order you want them prior to saving and submitting them. You are encouraged to use software that will create a PDF from another application’s data file, as this often produces a better quality PDF file and small file size, as described in the previous question. Q30: If I am using EFAST2-approved third party software to prepare a filing
for a client, how do I provide the plan sponsor/administrator signature (PIN) in
the submission?
If an annual return/report is signed and then exported or edited, the signatures are erased. If you export or edit it after it was signed, the plan sponsor or plan administrator will need to sign it again before the annual return/report is submitted. This applies whether you are using IFILE or EFAST2-approved third party software. Q31: Do you need a separate registration for the “Employer/Plan Sponsor”
and for the “Plan Administrator” (two separate signature lines) if the
Employer/Plan Sponsor and the Plan Administrator are the same person? If the same person serves as both the Plan Sponsor and Plan Administrator, that person only needs to sign as the Plan Administrator on the Plan Administrator line. Q32: I am a third party preparer that represents small businesses that do not
have their own computers. Can I register for Filing Signer credentials on their
behalf? Q33: I am a Plan Administrator that needs to electronically sign a Form 5500. Can I tell my preparer what my PIN is so they can sign and submit it for me? Q34: Do actuaries or accountants need to register for EFAST2 electronic filing
signer credentials? However, the Schedule MB and Schedule SB, if required, must be completed, printed, and signed by the actuary. An electronic image of the signed Schedule MB or Schedule SB with the actuary’s signature must be attached to the annual return/report. The information from the actuary’s Schedule MB or Schedule SB must also be entered into the appropriate location of the electronic Form 5500 or Form 5500-SF (including the Schedule SB or Schedules MB) being submitted. When entering the information, whether using EFAST2-approved third party software or EFAST2’s web-based filing system, all the fields required for the type of plan must be completed (see instructions for fields that need to be completed). The accountant must complete and sign their audit report on company letterhead. An electronic image of the signed accountant’s opinion must be attached to the annual return/report. The actuary and accountant electronic signature images are not EFAST2-issued electronic signature credentials and do not require registration for Filing Signer credentials. Submitting An Annual Return/Report (Form 5500 or Form 5500-SF) And Checking Its Status Q35: Can a third party preparer submit an annual return/report for the sponsor
electronically under EFAST2? Q36: I tried submitting a Form 5500 annual return/report and I received an
Acknowledgement ID. Does this mean my annual return/report was received? Q37: How do I check to see if a filing was received by EFAST2? The transmitter and filing signer also can check the status of the returns/reports they submitted or signed through the EFAST2 web site regardless of what software (IFILE or EFAST2-approved) was used to submit the filings. Any person (not just the transmitter or signer) can check the status of a filing by calling the EFAST2 Help Line at 1.866.GO-EFAST (1.866.463.3278) and using our automated voice system. The automated system will provide you with the status of the filing but will not describe any errors specific to the filing. Q38: How does the filing status tell me if an annual return/report is
considered “filed” in EFAST2?
Q39: How do I submit an amended annual return/report (Form 5500 or Form
5500-SF) for Plan Years 2009 and later in EFAST2? Q40: I am amending my Form 5500 (or Form 5500-SF) filing. Can I just submit
the portion of the return/report which I am amending? Q41: I need to submit an amended return for a Form 5500 that was previously
submitted on paper to EFAST. How do I file an amended return/report under
EFAST2? Q42: Will the general public be able to view all Form 5500 and Form 5500-SF
filings online? There are some filings that will not be disclosed on the web site. For example, if EFAST2 recognizes that a filer amended their filing, only the most recent (the amended) filing would be displayed on the web site. The original filing would not be displayed. Filings that are not shown on the EFAST2 web site will be available through the public disclosure room. Filings that were submitted through the current EFAST system will not be disclosed on the EFAST2 web site, but will continue to be available through the public disclosure system. Q43: How soon would EFAST2 filings become available to the public? Troubleshooting Problems With EFAST2 Q44: What should I do if the file size is “huge”? Submissions may include a batch of up to 100 filings. If a batch submission is over 100MB, the transmitter should break up the batch so that there are fewer filings in each batch submission. Based on the amount of data required to be submitted, a single filing should not exceed the 100MB size limit, even if the filing has multiple attachments. If a filing is bigger than 16MB, it is likely because the PDF attachments were scanned with too high of a resolution or color depth. Filers need to be aware of this when creating their attachments as PDF. See question 28 and 29 for ways to minimize file size when creating a PDF document. In the rare event a filing is over 100MB and you cannot reduce the file size of the attachments, please call the EFAST2 Help Line at 1.866.GO-EFAST (1.866.463.3278) and they will work with you to get the filing transmitted. Q45: Could pop-up blockers stop the display of
acknowledgement or any other messages that might be provided through the
filing process? Q46: Who can we contact about Form 5500 filing or
EFAST2 if we have questions or problems? |