SunGard Relius

In our continuing series of FAQs on EFAST2, we are addressing the issues and procedures with which the 5500 preparers and plan sponsors will need to familiarize themselves to make the transition to electronic filing. Probably one of the most significant challenges under EFAST2 for 5500 preparers will be the actual electronic filing. The steps vary depending on whether the 5500 preparer is using IFILE or a third-party web-based system. The following FAQs address the issues relating to the steps in filing electronically.

What are the steps a 5500 preparer will follow in filing a Form 5500 electronically under IFILE (or using third-party software uploaded to IFILE)?

After entering the data, the filing author (5500 preparer) will take the following steps:

1. Contact the plan sponsor through an e-mail option in IFILE and invite the plan sponsor to an electronic signing ceremony.
2. If the plan sponsor does not have signing credentials (filing signer), the contact will not occur. The filing author then will need to contact the plan sponsor through other means (telephone or e-mail) to encourage the plan sponsor to obtain the signing credentials.
3. The plan sponsor then will enter its signer ID and PIN code.
4. If the same individual signs as plan sponsor and plan administrator, the individual will need to repeat the signing ceremony.
5. The filing author will monitor IFILE to confirm the plan's sponsor has entered the signer ID and PIN code.
6. Once the filing author confirms that the signing credentials have been entered, the filing author must then transmit the Form 5500 filing to the DOL.
7. If the format is not correct, IFILE will inform the filing author of the error.
8. Once the filing has been recieved, the DOL has up to twenty-four hours to determine if it will accept the filing. The filing author can determine the plan’s filing status by monitoring IFILE.
9. If the filing is not accepted, IFILE will inform the filing author of the errors. The filing author will need to correct the errors and resubmit.

What are the steps a 5500 preparer will follow in filing a Form 5500 electronically under a third-party web-based system?

After entering the data, the 5500 preparer (no need for filing author credentials under a third-party web-based system) will take the following steps:

1. Contact the plan sponsor through an e-mail option and invite the plan sponsor to a signing ceremony.
2. If the plan sponsor has not obtained its signing credentials, the e-mail will provide a link and instructions on how to obtain the signing credentials. Note: Unlike IFILE, the 5500 preparer will be able to invite the plan sponsor to the signing ceremony irrespective of the whether the plan sponsor has obtained its signing credentials.
3. The plan sponsor then will enter its signer ID and pin code.
4. The plan sponsor then will submit the Form 5500 filing to the DOL.
5. The web-based system will optionally generate an e-mail to the 5500 preparer informing him/her when the filing has been submitted.
6. Within 90 seconds of the submission, the web-based system will indicate whether the Form 5500 filing is in a format which it may process.
7. The web-based system will automatically inform the 5500 preparer if the filing is in a format that can be processed If the format is not correct, the web-based system will inform the 5500 preparer of the error and how to correct the filing.
8. Once the filing has been received, the DOL has up to twenty-four hours to determine if it will accept the filing. The web-based system will optionally inform the 5500 preparer whether the filing was accepted.
9. If the filing is not accepted, the web-based system will inform the 5500 preparer of the errors. The 5500 preparer will need to correct the errors and resubmit.

Does the DOL consider a Form 5500 filed on the date it is submitted or on the date the DOL accepts the filing?

The DOL has indicated that if it accepts a submission within the twenty-four period, they will consider the Form 5500 filed on the date submitted. However, if the DOL does not accept the filing, the submission date is irrelevant.

Example: Corporation X submits its Form 5500 for its calendar year plan on the filing deadline - July 31, 2010. The DOL accepts the filing on August 1, 2010. X has timely filed its Form 5500.

Example: Assume the same facts except the DOL does not accept the filing. X has not timely filed its Form 5500.

How quickly will the DOL make a Form 5500 filing publicly available on its website?

The DOL has 90 days in which to make the Form 5500 publicly available. However, the DOL is indicating that it probably will be available much earlier.

5500 Workshop/401(k) Workshop. In our upcoming 5500 workshop, not only will we address all of the important questions and issues in the 5500, 5500-EZ, and schedules, we also will explain how to use and prepare effectively for EFAST2. We also have scheduled our 401(k) Plan Workshop to follow the 5500 Workshop. The topics for the 401(k) Workshop include the Suspension of the Required Minimum Distribution;, PPA ’06 Technical Corrections; New Guidance of Permissive Disaggregation; Safe Harbor 401(k) Plan Design; Participants in Financial Difficulties: loan defaults, hardship distribution and QDROs; and Complex Testing of Ordinary Allocations; and Penalties and Additional Income Taxes. For more information on the seminars, click here.

The 5500 Filing Guide is a comprehensive guide to completing the 5500 (and schedules) effectively and efficiently. The recently updated book not only includes practical explanations of each line on all the forms and schedules, but it also provides hundreds of examples and FAQs. For information on how to order the book, click here.

Relius Government Forms. SunGard’s Relius Government Forms 5500 Web Client is a secure, interactive, online solution that can help you and your clients meet the challenges posed by EFAST2. For more information, see our Web site.

Question and Answer Pamphlet on EFAST2. To help 5500 preparers explain the changes made by EFAST2, SunGard has prepared a Q&A pamphlet to answer the employers’ questions. Find out more here.