For the first time, it is mandatory for benefit plans to file the Form 5500 electronically with the Department of Labor (DOL) using their new EFAST2 system. With the predecessor system, known as EFAST1, the DOL made electronic filing possible, but not mandatory. EFAST2 opened for registration on January 2, 2010 and its use is now required for welfare plan and retirement plan filings, including all 403(b) plans subject to Title I of ERISA, submitted for years beginning on or after January 1, 2009.
Electronic filing is not available for Form 5500-EZ; however, Form 5500-SF may be submitted online in lieu of Form 5500-EZ, as long as the filer is eligible to file the Form 5500-SF.
In order to file electronically, every person who touches a Form 5500 in any way, including the signers, will need to register with EFAST2 to obtain a unique user name and PIN, commonly referred to as a credential. The DOL is limiting one set of credentials per email address, and each individual attempting to obtain a credential must apply for himself or herself. That is, preparers are not allowed to obtain signature authority for their clients.
To obtain credentials, log into I-REG at www.efast.dol.gov, and go through the series of input screens which will ultimately result in the assignment of a credential. A User ID and PIN will be assigned – which should be saved to access the credential.
Once the credential has been obtained, authorized parties can prepare the Form 5500. Upon its acceptance by the DOL, the Form will be posted on the internet within a very short period of time. One important note - it is absolutely critical to leave social security numbers off the Form. The DOL will reject any filing containing such a number.
By Bob Cann, CPA, Partner, Director of Compliance Services, rcann@legacycpas.com