Benefit Plan Alert - E-filing for 5500s and Safe Harbor for Small Plans
DOL mandates electronic filing for Form 5500
The DOL is moving to electronic filing of all Form 5500s starting Jan. 1, 2010. Electronic filing is mandatory. They will not accept paper filings for plan years beginning on or after Jan. 1, 2009.
There are two signatures required for the 5500 – the plan administrator and the employer/plan sponsor. It is possible that both signature lines will be signed by the same person. If two different people will be signing, both will need to register separately. In order to sign the Form 5500, you will need to obtain “filing signer” credentials. The DOL will not permit any outside service providers to obtain the credentials on behalf of the signers. To obtain the filing signer credentials, these individuals must register on the DOL’s website.
As a part of the registration process, you will be given a user ID, PIN, and you will create a password. These three pieces of information are very important. Please retain this information in a safe place. You will need all three to sign your return.
Please note: If BMF prepares your return electronically, part of this procedure will require you to enter your user ID and PIN on our computer system via an electronic meeting. We will provide step-by-step instructions of how to sign your return when we send you the client copy of your Form 5500.Registration Instructions
- Go to the website http://www.efast.dol.gov
- On the left hand side of the screen there is a menu. Under Main, click on Register
- Read the agreement, click the box stating you have read it, and click on Accept Agreement
- Fill in the information requested – under User Type, select Filing Signer, then click Next
- Select one of the challenge questions, enter the answer, then click Next
- Verify that all the information entered is correct, then click Submit
- A screen should appear that states Registration Success!!, click OK
- You will be brought back to the home screen. The system will send you an e-mail.
- Check your e-mail for a message from efast2@efastsys.dol.gov (may go to your junk email folder, so be sure to look there)
- The e-mail will contain a link, click on the link
- You will be brought to a screen and asked to answer your challenge question. Enter the answer, then click Next
- Read the agreement, click the box stating you have read it, and click on Accept Agreement
- A screen will appear titled Register – Finalize - **PRINT THIS PAGE** Once printed, click Next
- You will be prompted to create your password. Note the password requirements on the right-hand side of the page. Enter it twice and click Next
- You should see a screen titled Register – Confirmation
- We suggest writing your password on the printed page. The printed page contains your User ID and PIN. Save this page in a safe place.
- On the left-hand side of the screen in the menu, click Login
- Using the User ID and password, attempt to login to the system. If you are successful, congratulations, you’re all set for now!
If you have any questions or have trouble in obtaining the credentials, please contact Cindy Mitchell, CPA at 330.255.2454 or by email.
DOL establishes safe harbor period for participant contribution deposits for small plans
The DOL recently established a safe harbor period for certain employers to deposit contributions on a timely basis. At the beginning of the plan year, participant contributions to a pension or welfare benefit plan with fewer than 100 participants will be treated as having been made to the plan on the earliest date such contributions can reasonably be segregated from the employer’s general assets (i.e. in accordance with the general rule), as long as contributions are deposited no later than the seventh business day following the day on which such amount is received by the employer OR the seventh day following the day on which such amount would otherwise have been payable to the participant in cash.
What about large plans?
At this time, the DOL is not extending the safe harbor provision to cover participant contributions to a pension or welfare benefit plan with 100 or more participants. The DOL does not believe it has a sufficient record to evaluate current practices and assess costs, benefits and risks to participants associated with extending the safe harbor or any variation thereof to large plans.
To help you understand the impact of these regulations, or if you have questions about this or other matters affecting your benefit plans, please contact Partner Jim Merklin, CPA, CFF, CFE at 330.255.2448 or by email.