New 5500 Filing System
The Department of Labor (DOL) has new requirements for 5500 filings that include mandated electronic filing. Plan years beginning on or after January 1, 2009, MUST be filed electronically using the ERISA FIling Acceptance System II (EFAST2).
Plan year 2008 filings (including late and amended filings) can be submitted electronically using EFAST2, electronically using EFAST, or on paper until October 15, 2010.
- Prior to EFAST2, plan sponsors often received a completed Form 5500 from the plan's TPA or accountant with instructions indicating where to sign and mail. Plan sponsors will no longer receive a paper copy of the return that will need to be signed and mailed. Paper files will be for the plan's records only.
- Plan administrators are now REQUIRED to sign the form electronically
- Plan administrators must register at www.efast.dol.gov for EFAST2 electronic credentials to sign Form 5500. Registration instructions for EFAST2.
Please note:
- If your Form 5500 is prepared by a third party, you cannot share your credentials
- The plan administrator and the third party preparer will need to coordinate how the plan will electronically sign the return
- New electronic credentials are required even if the plan already has a PIN and ID for electronically filing under EFAST
- If the plan is required to submit a report from an independent qualified accountant, the document should be attached to Form 5500 as a PDF file
- Nearly all filings submitted through EFAST2, including schedules and attachments, will be available to the general public through the DOL website
- The Form 5500 series no longer includes Schedule SSA. If a social security number is included anywhere on Form 5500, the filing may be rejected
If you have any questions or concerns regarding the new filing requirements, please contact your accountant or TPA.