April 23, 2010
An important filing requirement changed on January 1, 2010, for employers who have employee benefit plans and file the Form 5500. On this date, employers became required to file their 5500 Form and 5500 Short Form annual returns and reports electronically.
The Department of Labor has established an electronic filing system called ERISA Filing Acceptance System II, or EFAST2, to simplify and expedite receipt and processing of 5500 forms. The person who signs the return must register for filing credentials through the EFAST2 system. An e-mail address and internet access are crucial to register. You can obtain filing credentials at any time, but the DOL recommends applying sooner rather than later.
The second part of the ERFAST2 system involves filing the return. Your software provider will have its own method of providing a signature-ready Form 5500, so check with them to verify their process. In most cases, the preparer uploads the Form 5500 onto the EFAST2's internet filing system and invites the signer to electronically sign it and submit it to the EFAST2's filing acceptance system.
Larger plans are also required to attach their independent audit report to the Form 5500. The audit must be included as an attachment to the Form 5500 filing.
Plan sponsors must still maintain a copy of the complete Form 5500 filing on file, either in paper form or in electronic form if the required manual signatures are captured in the electronic version.
The DOL has a number of resources regarding the EFAST2 system, including a user's guide, frequently asked questions and webcasts at www.dol.gov. Live support is also available by phone from 8:00 a.m. to 8:00 p.m. Monday through Friday at 866-GO-EFAST (866.463.3278). Your Rea advisor can also assist you with this process.
Darlene Finzer, CPA, CSA, QKA (New Phila office)