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Do you File a Form 5500 or 5500-SF?

YOU WILL WANT TO READ THIS!

The days of dropping your paper copy 5500 package in the US mail by the deadline are over! Beginning with 2009 5500s, a new all-electronic 5500 filing system called “EFAST2” must be utilized to submit 5500s and any required attachments (e.g., audit reports).

There are some things you can do now to get ready for this new process:

1. Follow the link below to the DOL's Frequently Asked Questions document available at www.dol.gov/ebsa/faqs. Click on EFAST2 Form 5500 Processing under compliance assistance. This Q&A document will provide answers to many of your EFAST2 questions.

2. Register for electronic credentials through EFAST2:

    a. Log on to the www.efast.dol.gov website.
    b. Click on "Register."
    c. Get email notification from EFAST2.
    d. Click on the link in the EFAST2 email to complete your registration.
    e. Obtain and retain your User ID and PIN.

WE RECOMMEND YOU DO THESE STEPS AS SOON AS POSSIBLE. You will need to determine what type of user you are - a filing author, a filing signer, a schedule author, a transmitter, or a third-party software developer. There are important distinguishments between the various roles, which are defined in the Q&A in question 11.

It is critical to note that the signers of the 5500 (regardless of service providers involved) must register for credentials to sign a Form 5500 under EFAST2. Also, note that you will need a new PIN and ID for EFAST2. IDs and PINS set up previously in the old EFAST system will not work in EFAST2.

3. Determine which service providers, if any, will be involved in the process and develop a plan. These discussions should include the determination of:

    a. Roles and responsibilities (filing author, signer, transmitter, etc.)
    b. Software to be utilized (third-party approved software or the DOL’s IFILE system)
    c. Timeline for preparation, review and submission of the filing, and related attachments (it is in your best interest to NOT wait until the deadline to complete your filing)
    d. Filing of extensions, if any
    e. Any other logistical matters (location of signers, access to computers, authorization to service providers to sign the 5500, etc.)

4. If your 5500 requires an audit report to be attached to your 5500 filing, be sure to coordinate with your auditor to obtain a final signed report, with the audit report on your accounting Firm’s letterhead, saved as a PDF file. Also, determine the audit timeline and estimated date for completion. This file will be attached to the Form 5500 and will be transmitted to EFAST2 along with the rest of the information in the 5500.

Help is available if you need it - The Barnes Wendling Employee Benefit Plan Group will help you with any questions you may have. Please contact Rosie Rehner or Laure Javorsky at 216-566-9000 or email us at ebaudits@barneswendling.com. The DOL also offers the EFAST2 Help Line - 1-866-463-3278, or 1-866-GO-EFAST.

TAKE NOTE!

In addition to the electronic filing changes noted above, all schedules and attachments, INCLUDING THE AUDIT REPORT, will become available to the general public through the DOL Website www.efast.dol.gov generally within ONE DAY of receipt. Be sure to check your filing and all attachments for any personal information that should not be disclosed to the public.