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All pension and welfare plans and DFEs that are required to submit an annual return/report under Title I of ERISA (Form 5500 or Form 5500-SF) must do so electronically for plan years beginning on or after January 1, 2009. Beginning January 2010 an all-electronic system called EFAST2 will receive those electronic annual returns/reports. Once the EFAST2 electronic system is on-line and ready to receive filings, you must file the Form 5500 or Form 5500-SF electronically through EFAST2 for plan/reporting year 2009 and for subsequent plan/reporting years. Prior year delinquent or amended Form 5500 annual return/reports generally must be filed electronically through EFAST2. See question 4.
The Form 5500-EZ cannot be submitted electronically. A “one-participant”
plan (see the instructions for the Form 5500-SF) that is eligible to file Form
5500-EZ and is not required to file under Title I of ERISA may elect to file
Form 5500-SF electronically with EFAST2 rather than filing a Form 5500-EZ on
paper with the IRS. Such a “one-participant plan” that is not eligible to
file Form 5500-SF must file Form 5500-EZ on paper with the IRS. For more
information on filing the Form 5500-EZ, see the instructions for Form 5500-EZ,
go to www.irs.gov, or call 1.877.829.5500.
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On This Page
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You have several options:
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You can electronically file a plan year 2008 annual return/report using
EFAST2-approved third party software or IFILE beginning January 2010. EFAST2 is
the new filing system.
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You can electronically file a plan year 2008 annual return/report using
EFAST-approved third party software until June 30, 2010. EFAST is the current
filing system.
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You can file a plan year 2008 annual return/report on paper through the
current EFAST filing system, using EFAST-approved software or government-issued
hand print forms, until October 15, 2010.
Short 2009 plan year filers whose due date to submit their 2009 filing is
before January 1, 2010 will be given an automatic extension to electronically
file their complete Form 5500 annual return/report within 90 days after the 2009
filing system is available on the DOL web site. This special extension is being
granted to encourage such filers to submit their 2009 returns/reports
electronically under EFAST2. Filers who choose not to take advantage of the
special extension must use plan year 2008 forms and instructions and submit
their annual return/report on or before the due date for their filing under the
current EFAST system (before EFAST2 and the 2009 Forms and instructions are
available for filing in January 2010).
Beginning January 1, 2010, delinquent and amended filings of Title I plans must be submitted through EFAST2 and cannot be submitted through the current EFAST system. A limited exception is available, however, for delinquent and amended 2008 plan year filings. Specifically, you may submit a delinquent or amended 2008 plan year filing through EFAST on paper until October 15, 2010 or electronically until June 30, 2010. Further guidance on the exact steps required to submit delinquent or amended Form 5500 returns/reports through EFAST2 will be provided later.
IFILE is the Form 5500 and Form 5500-SF annual return/report preparation and
submission application that will be on DOL’s web site www.efast.dol.gov.
No. IFILE is offered as an alternative to EFAST2-approved third party
software.
A list of EFAST2-approved third party software will be posted on
www.efast.dol.gov. There will be two types of software certification in EFAST2:
certification for software to prepare filings and certification for software to
submit filings. Make sure the software you are using is approved for the
function(s) you will need to have performed by the software (i.e., filing
preparation and/or submission).
Historically, 90 percent of filers have used approved third-party software.
Continuing to use approved third-party software will provide you with continuity
in the switch to the new system, which should help minimize the possibility of
technical issues.
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.
You may be able to use the same type of third-party software that you have
been using to prepare your Form 5500, but you need to ensure that the version
you use is approved for the 2009 plan year by EFAST2. A list of EFAST2-approved
third party software will be posted on www.efast.dol.gov.
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.
Once EFAST2 is operational in January 2010 you can begin registering for
electronic credentials through the EFAST2 web site www.efast.dol.gov.
There are five user types under EFAST2. You can check as many as apply to
you. You may associate more than one user type under your registration if you
will be performing multiple functions:
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.
You do not need to register for EFAST2 electronic credentials just to
complete the annual return/report using third party software. If you will be
submitting the filing to EFAST2, however, you will need to register for
credentials as a “Transmitter” user type. If you will be signing the filing,
you will need to register for credentials as the “Filing Signer” user type.
A Filing Author is the person who initiates (including filling out) the Form
5500 or Form 5500-SF and the schedules and attachments on IFILE. A Transmitter
is the person or organization who actually submits the completed annual
return/report to EFAST2.
You will need to get Third-Party Software Developer credentials (see question
11).
There are two separate credentials for third party software: (1) for filing
preparation software; and (2) for filing transmission software.
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.
No. EFAST2 is a completely separate system from EFAST. You will need to
register for and obtain new electronic credentials under EFAST2.
After successfully logging into the EFAST2 web site, click on the “Profile”
link in the navigation bar and you will be able to change any of your contact
information, including email address.
The only schedules required to be filed with the Form 5500-SF for a plan that
is covered by Title I are the Schedule SB (actuarial information) for defined
benefit pension plans or Schedule MB (actuarial information) for money purchase
plans that are amortizing funding waivers. No other schedule should be submitted
with the Form 5500-SF.
If you are filing the Form 5500, you must submit all required schedules and
attachments, including the Schedule D, if applicable.
Beginning with the 2009 plan year, the Form 5500 series does not include the
Schedule SSA. Do not find a prior year Schedule SSA, fill it out and attach that
to your 2009 Form 5500 filing! Do not try to create your own Schedule SSA and
attach that to your Form 5500 filing! SSA information will be collected by the
IRS.
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).
Using your filing preparation software, you can view your annual
return/report as it would appear populated in a form facsimile. In IFILE, you
can click the “View as PDF” button to see your annual return/report in a
facsimile format. If you are using EFAST2-approved third party software, check
your user manual for instructions on how to view your annual return/report in a
facsimile format.
If you have a draft annual return/report (Form 5500 or Form 5500-SF) that you
wish for other people to review, you can export the draft annual return/report.
When you do that, you will have an XML file that you can send to other
individuals. Those individuals can import the XML file into their
EFAST2-approved third party software or into IFILE to review. If they wish to
make changes to the draft annual return/report, they can do so, but they need to
export the revised annual return/report into an XML file and send that back to
you for the changes to be included in the transmission to EFAST2.
Yes. You can (and should) “validate” your filing before submitting it.
The automatic validation will perform an initial check for errors, such as if
Schedule H numbers are not consistent within Schedule H or with the Form 5500.
This is a check of errors in your filing before you submit it to the Government.
If the errors/warnings are not corrected before submission, the Government will
be alerted to the errors associated with your filing when it is submitted.
Please run the pre-validation check and correct any errors/warnings to the best
of your ability before you submit your filing.
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.
Please do not submit a draft annual return/report to EFAST2. When you
"submit” an annual return/report, you are sending it to the Government.
Do not submit a draft annual return/report to EFAST2 simply because you
or your client wish to see what the filing will look like after it is filed. If
you wish to view a completed annual return/report in IFILE, see the IFILE Users’
Guide. Also, see questions 20 and 21 for additional information on reviewing and
checking your file before submission.
If the numeric answer to the question is zero, or if the question provides
that you cannot leave it blank, then enter “0“. Only leave a numeric field
blank where the instructions specifically permit you to do so.
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.
The IQPA report needs to be documented on letterhead, signed, and then saved
as a single Portable Document Format (PDF) file. That PDF file then needs to be
attached to the Form 5500 annual return/report. When you submit the Form 5500
annual return/report, the attachments will be transmitted to EFAST2 along with
the rest of the information in the annual return/report.
The EFAST2 system will receive your filing, but submitting the annual
return/report without the required IQPA report is an incomplete filing, and the
incomplete filing may be subject to further review, correspondence, rejection,
and assessment of civil penalties. Also, if you do not submit the required IQPA
report, you must still correctly answer the IQPA questions on Schedule H, line
3. This means you must leave lines 3a and 3b blank because the IQPA report is
not attached and must also leave line 3d blank because the reason the IQPA
reports is not attached (i.e., is was not completed on time) is not a reason
listed in any of the available check boxes. You should still complete line 3c if
you can identify the plan’s IQPA. Please note that failing to include the
required IQPA report and leaving parts of line 3 blank, however, will result in
the system status indicating that there is an error with your filing because, as
noted above, submitting your annual return/report without a required IQPA report
is an incomplete filing, and the incomplete filing may be subject to further
review, correspondence, rejection, and assessment of civil penalties. Thus, if
you find it necessary to file a Form 5500 without the required IQPA report, you
must correct that error as soon as possible.
You do not need to attach a copy of the Form 5558 that was filed with the
Internal Revenue Service to the annual return/report in EFAST2. You must,
however, keep a copy of the Form 5558 that was filed with the Internal Revenue
Service with the plan’s records.
The IQPA report, image of the signed Schedule MB, and image of the signed
Schedule SB must be submitted in Portable Document Format (PDF). All other
attachments can be submitted in either PDF or plain text format (TXT).
Using software that will create a PDF file from another software application’s
data file often provides the best quality PDF and small file size. There are
many software options for creating PDFs by “saving as” a PDF file or “printing”
to a PDF file rather than a printer. When you are creating a PDF file using such
software, you often must have the application that created the original file
installed on your computer. You can also create a PDF file by using other free
and paid software programs that you may already be using on your personal
computer, regardless of your operating system.
Scanners generally come with software that includes an option to save a
scanned document as a PDF. Look for menu items such as “output type” or “settings”
to select PDF as the output file type. Consult your scanner’s user manual for
specific instructions.
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.
There are a few alternatives:
- Your EFAST2-approved third party software may have a
file sharing function (see question 8) that allows a plan sponsor to view and apply their signature to the
filing. Check with your software vendor or user’s manual to see if the
software vendor offers this function.
- You can use IFILE as a medium to share the filing with
the plan administrator/plan sponsor. How you do that depends on whether
you want to submit the filing or whether the plan administrator/plan
sponsor wants to submit the filing. It also depends on whether the plan
administrator/plan sponsor wants the ability to make changes to the
annual return/report before submission. The person who will submit the
filing needs to import it into IFILE as explained below.
- If you expect to submit the filing, you would need
to export the annual return/report from your EFAST2-approved third
party software to an XML file. You can import the XML file into
IFILE. After the file is imported into IFILE, you would need to
specify the plan administrator/plan sponsor as the signer by
entering the plan administrator/plan sponsor’s email address. If
the plan administrator/plan sponsor had not yet registered in EFAST2
as a Filing Signer, you will be alerted at this time. The plan
administrator/plan sponsor would login to IFILE using their EFAST2
electronic credentials. The plan administrator/plan sponsor would
not be able edit the filing but would be able to view and sign the
filing. Once the filing is signed, you could then submit it. The
Filing Signer, however, retains legal responsibility for the
timeliness of the submission, as well as for its accuracy and
completeness.
- If the plan administrator/plan sponsor wants to
submit the filing, you would need to export the annual return/report
from your EFAST2-approved third party software to get an XML file
that you would send to the plan administrator/plan sponsor. The plan
administrator/plan sponsor would need to have already registered in
EFAST2 as a Filing Author and as a Filing Signer. The plan
administrator/plan sponsor can login to IFILE and import the XML
file generated by the third party software into IFILE. The plan
administrator/plan sponsor can then review and edit the annual
return/report in IFILE. Then the plan administrator/plan sponsor
would identify himself when registering as the Filing Signer. Once
the plan administrator/plan sponsor signs the filing, he or she
could then submit it.
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.
No, you only need to register one time for both purposes. The credentials
that you get can be used for multiple years and on multiple filings.
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.
No. The EFAST2 process for obtaining Filing Signer credentials is designed so
that the person signing electronically must be the person registering for the
credentials. Access to any computer with an Internet connection is all that is
required to register. Thus, your client may come to your office, use a personal
computer at home, or go to a public library or copying center with a computer,
and register for credentials using free email accounts or an email account provided by your company (e.g., tpafirm.com).
As the Plan Administrator, the Form 5500 or 5500-SF that will be sent to EFAST2 must be examined by you before it is submitted. Your signature attests that has been done and that, to the best of your knowledge and belief, it is true, correct, and complete. Since the EFAST2 PIN is the plan administrator/sponsor/DFE's electronic signature for purposes of the Form 5500 and Form 5500-SF, PINs must be protected and not shared. We appreciate the fact that some filers may find it easier to comply with the electronic signature requirement if PIN sharing were permitted. However, we believe plan administrators and other filers will be able to comply with their annual reporting obligations within the EFAST2 system PIN requirements even if some filers will need to adjust their practices to address individual challenges.
No. EFAST2 does not require EFAST2-issued electronic signature credentials
for anything other than for filing and submitting the Form 5500 and Form
5500-SF.
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.
Yes. A third party preparer can submit an annual return/report that a plan
sponsor/administrator has already signed electronically. The plan
sponsor/administrator, however, retains legal responsibility for the timeliness
of the submission, as well as for its accuracy and completeness. See question 30,
above, regarding signing an annual return/report.
An Acknowledgement ID means EFAST2 received an electronic “envelope” but
it does not necessarily mean EFAST2 received the “filing” (i.e., the Form
5500 or Form 5500-SF, including all required schedules and attachments)
inside the envelope. You need to check the filing status to ensure EFAST2
received your filing.
The individual who transmitted the annual return/report to EFAST2 or the
signer(s) of that return/report can check
the filing status, using the software used to submit the annual
return/report, approximately 20 minutes after submission. 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.
If the filing status states “Filing_Received,” “Filing_Error,” or “Filing_Stopped,”
then the annual return/report is considered received. However, filings with a
status of “Filing_Error” or “Filing_Stopped” must be corrected through
an amended filing. Below is a chart summarizing the submission and filing
statuses and what they mean. By looking closer at the Filing Status, you can see specific error messages
applicable to the transmitted filing.
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Return/Report
Considered
A Filing? |
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Unprocessable
Submission |
EFAST2 was not able to process the submission or “envelope”
a transmitter sent. There may be multiple returns/reports in a single
submission. EFAST2 could not read or process any of the annual returns/reports
in this submission. All returns/reports in this submission are considered not
received by the Government. |
No -
This submission must be corrected and
re-submitted. |
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Processable
Submission |
EFAST2 was able to process the submission or “envelope”
a transmitter sent. There may be multiple annual returns/reports in a single
submission. EFAST2 will next need to try to read and process each of the annual
returns/reports in this submission. |
No -
The annual return/report(s) may not have
been processed. |
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Processing |
EFAST2 is currently trying to read and process each of the annual
return/report in the submission. Annual returns/reports should not remain in
this status for more than 20 minutes. |
No -
The annual return/report has not
yet been processed. Please check the filing status at a later time to determine
the annual return/report’s processing outcome. |
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Filing
Unprocessable |
EFAST2 could not read this annual return/report. This
annual return/report is not considered filed with the Government. |
No -
This
annual return/report must be corrected and resubmitted. |
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Filing
Stopped |
EFAST2 could read this annual return/report but could not
fully check the filing for errors because crucial information was not provided
by the filer. This annual return/report must be corrected and resubmitted in its
entirety as an amended filing. |
Yes |
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Filing Error |
EFAST2 discovered errors in the annual return/report information
provided by the filer. This annual return/report must be corrected and
resubmitted in its entirety as an amended filing. |
Yes |
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Filing
Received |
EFAST2 either found no errors or only identified possible
errors in the annual return/report information provided by the filer. If
corrections are warranted, they should be made and the corrected filing
resubmitted in its entirety as an amended filing. |
Yes |
For plan years 2009 and later, starting with the original version you
submitted, make the necessary amendments, check the box for “amended
return/report” in Part I, and resubmit the entire annual return/report,
including all needed schedules and attachments.
No. You will need to resubmit the entire Form 5500 (or Form 5500-SF), with
all required schedules and attachments, through EFAST2. You cannot submit just
the parts of the filing that are being amended.
You would have to submit an entire Form 5500, including any schedules and
attachments, electronically through EFAST2. See question 4.
Nearly all filings submitted through EFAST2, including schedules and
attachments, will be available to the general public through the DOL web site
www.efast.dol.gov. You do not need to register for electronic credentials or
login to the EFAST2 web site to access the EFAST2 public disclosure web site.
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.
The EFAST2 web site generally will be able to display submitted filings within
one day of receipt. The public disclosure room will have filings in
approximately that same amount of time.
EFAST2 should accept any submissions up to 2GB in file size. It is
possible that a filer would not be able to transmit a submission under the
EFAST2 limit of 2GB due to issues on their end of the network or due to
their Internet Service Provider.
Submissions may include a batch of up to 100 filings. If
a batch submission is over 2GB, 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 2GB 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 2GB 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.
Yes. Please consider turning off pop-up blockers in your web browser
when using the EFAST2 web site.
Please begin by calling the EFAST2 Help Line at 1.866.GO-EFAST (1.866.463.3278).
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