EFAST2 Webcast June 2010 (Final)

8/8/2019 EFAST2 Webcast June 2010 (Final)

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Attachment Tips

DonDon ’’t include old Form 5500 Schedule SSA, t include old Form 5500 Schedule SSA, new Form 8955new Form 8955‐‐SSA, social security numbers, SSA, social security numbers, passwords, or other private information in passwords, or other private information in attachments to your 2009 and later filings. attachments to your 2009 and later filings. Generally, these will be posted on the Internet. Generally, these will be posted on the Internet.

Your account may be revoked.Your account may be revoked.

DonDon ’’t scan your attachments unless itt scan your attachments unless it’’s s necessary. If you must scan, necessary. If you must scan,

••

Set your scanning resolution to 300 DPI.Set your scanning resolution to 300 DPI.••

Optimize or reduce the resulting file size if Optimize or reduce the resulting file size if your scanner or PDF software has such a your scanner or PDF software has such a

function.function.EBSA



Attachment Tips, cont.

Upload each attachment into the correct type.Upload each attachment into the correct type.

If you

have

several

hundreds

of

pages

of

If

you

have

several

hundreds

of

pages

of

attachments for a single filing, IFILE may not attachments for a single filing, IFILE may not work well for you. Evaluate your needs and work well for you. Evaluate your needs and see how third party software may better see how third party software may better support you.support you.

EBSA



Filing Completion Tips

Turn off pop up blockers if using IFILE.Turn off pop up blockers if using IFILE.

Validate before signing & submitting. Validate before signing & submitting. Otherwise, youOtherwise, you ’’ll need to submit an ll need to submit an amended filing to fix errors.amended filing to fix errors.

The validation may point out The validation may point out inconsistencies. The EFAST2 system inconsistencies. The EFAST2 system wonwon ’’t necessarily point out the correct t necessarily point out the correct answer, but you may be able to check on answer, but you may be able to check on your own. Call the help desk with your own. Call the help desk with

questions.questions.EBSA



Filing Completion Tips, cont.

If amending, you must send the entire If amending, you must send the entire

Form 5500

including

all

schedules

and

Form

5500

including

all

schedules

and

attachments. attachments.

When your return/report is all filled out When your return/report is all filled out

(complete), you should export an (complete), you should export an electronic copy of the filing for your electronic copy of the filing for your records. records.

EBSA



Filing Submission Tips

Be sure to check the status of your filing after Be sure to check the status of your filing after submission. It should say submission. It should say ““Filing ReceivedFiling Received ””

Click to see if there are errors or warnings. Click to see if there are errors or warnings.

If the status is If the status is ““Filing ReceivedFiling Received ””

and no and no

warnings are listed, you do not need to do warnings are listed, you do not need to do anything further unless you receive followanything further unless you receive follow ‐‐up up correspondence from a Government agency. correspondence from a Government agency.

If the status is anything other than If the status is anything other than ““Filing Filing Received,Received, ””

correct the errors or warnings listed correct the errors or warnings listed

and submit an amended return to avoid and submit an amended return to avoid potential correspondence and imposition of potential correspondence and imposition of

penalties.penalties.EBSA



Review & Wrap Up

Electronic Filing MandateElectronic Filing Mandate

What WeWhat

We ’’re

Hearing

About

EFAST2

From

re

Hearing

About

EFAST2

From

Filers and StakeholdersFilers and Stakeholders

What WeWhat We ’’ve Done About It & The Eve Done About It & The E‐‐Signature Signature OptionOption

The Past Six Months & The Next Four MonthsThe Past Six Months & The Next Four Months

Registration TipsRegistration Tips

Attachment TipsAttachment Tips

Security TipsSecurity Tips

Filing Completion TipsFiling Completion Tips

Filing Submission TipsFiling Submission Tips

EBSA



Form 5500/5500Form 5500/5500 --SFSF



Who Files and What to File

Rules mostly unchanged on who files and Rules mostly unchanged on who files and whatwhat

BUT people are more aware that they may BUT people are more aware that they may have had a filing requirement and are now have had a filing requirement and are now asking the basic questionsasking the basic questions

Biggest change on who and what: Biggest change on who and what: ••

403(b) plans now report like other pension 403(b) plans now report like other pension plansplans

••

New Form 5500New Form 5500‐‐SF for eligible small plansSF for eligible small plans

What to file for large welfare plans clarified in What to file for large welfare plans clarified in instructionsinstructions

EBSA



Getting Started

Do I have to file?Do I have to file?

Can I file

the

Form

5500Can

I file

the

Form

5500

‐‐SF?SF?

What schedules do I have to complete?What schedules do I have to complete?

What questions on the Form and Schedules do What questions on the Form and Schedules do

I have

to

answer?I

have

to

answer?

EBSA



Where to Get Answers

General instructions, including General instructions, including ““Quick Quick Reference Chart.Reference Chart. ””

Questions and text on face of Forms and Questions and text on face of Forms and Schedules.Schedules.

Instructions by Form and Schedule.Instructions by Form and Schedule.

Additional Guidance:Additional Guidance:••

Regulations referenced in instructions.Regulations referenced in instructions.

•• FAQs.FAQs.

••

Guides and tips.Guides and tips.

EBSA



Pension Plans—Who Files

Most private employerMost private employer ‐‐sponsored pension sponsored pension plans have to file either the Form 5500plans have to file either the Form 5500‐‐SF or SF or the Form 5500 and its schedules and the Form 5500 and its schedules and attachmentsattachments

Which form and which schedules depends on Which form and which schedules depends on size, nature of plansize, nature of plan ’’s investments, plan s investments, plan activities during the year, and type of planactivities during the year, and type of plan

Some plans are exempt from filingSome plans are exempt from filing

EBSA



Pension Plans that Don’t File

Unfunded excess benefit plansUnfunded excess benefit plans

Plans not

covered

by

Title

I of

ERISAPlans

not

covered

by

Title

I of

ERISA

403(b) plans that meet the terms of DOL403(b) plans that meet the terms of DOL ’’s s ““safe harborsafe harbor ””

regulation at 29 CFR 2510.3regulation at 29 CFR 2510.3‐‐

2(f)2(f)

Church pension benefit plan not electing Church pension benefit plan not electing coverage under Code section 410(d)coverage under Code section 410(d)

Foreign plansForeign

plans

Governmental plansGovernmental plans

IRAIRA’’s or annuities not considered plans s or annuities not considered plans

under 29

CFR

2510.3under

29

CFR

2510.3

‐‐2(d)2(d)

EBSA



Pension Plans that Don’t File,cont.

SEPsSEPs

that meet the alternative method of that meet the alternative method of

compliance in 29 CFR 2520.104compliance in 29 CFR 2520.104‐‐48 or 49.48 or 49.

Unfunded dues financed pension benefit plan Unfunded dues financed pension benefit plan that meets the alternative method of that meets the alternative method of compliance in 29 CFR 2520.104compliance in 29 CFR 2520.104‐‐2727

EBSA



Limited Reporting for Certain

Pension Plans

Limited Reporting:Limited Reporting:

••

IRA Plans

using

individual

retirement

IRA

Plans

using

individual

retirement

accounts or annuities (as described in Code accounts or annuities (as described in Code section 408)section 408)

••

Fully insured pension plansFully insured pension plans

EBSA



5500-SF Eligible Small Pension

Plans – What to File

Form 5500Form 5500‐‐SF eligible:SF eligible:

••

Form 5500Form 5500‐‐SFSF••

No schedules or attachments except:No schedules or attachments except:

Schedule MB for money purchase plans;Schedule MB for money purchase plans;Schedule SB for defined benefit pension Schedule SB for defined benefit pension plans.plans.

••

If electing eIf electing e‐‐signature alternative, attach signature alternative, attach

PDF of manually signed Form 5500PDF of manually signed Form 5500‐‐SF to eSF to e‐‐ filing.filing.

EBSA



Small Pension Plans Not 5500-SF Eligible – What to File

Form 5500 (including PDF of manually signed Form 5500 (including PDF of manually signed 5500 if using e5500 if using e‐‐signature alternative)signature alternative)

Schedule A, if applicable, for insurance Schedule A, if applicable, for insurance informationinformation

Schedule D, if applicable, for info on Schedule D, if applicable, for info on investments in DFEsinvestments in DFEs

Schedule G, if applicable, to report nonSchedule G, if applicable, to report non ‐‐exempt exempt transactionstransactions

Schedule I for financial informationSchedule I for financial information

Schedule R for retirement plan informationSchedule R for retirement plan information

EBSA



Small Pension Plans Not 5500-SF Eligible – What to File, cont.

Schedule MB only for multiemployer defined Schedule MB only for multiemployer defined benefit plans and money purchase plans benefit plans and money purchase plans

Schedule SB only for single employer defined Schedule SB only for single employer defined benefit pension plans benefit pension plans

If meet the requirements of 29 CFR 2520.104If meet the requirements of 29 CFR 2520.104‐‐46 46 (small plan audit waiver regulation) don(small plan audit waiver regulation) don ’’t need t need to file IQPA report.to file IQPA report.

EBSA



Large Pension Plan Filing—

What to File

Form 5500 (including PDF of manually Form 5500 (including PDF of manually signed 5500 if using esigned 5500 if using e‐‐signature alternative)signature alternative)


Schedule C for service provider Schedule C for service provider informationinformation

Schedule D, if applicable, for information Schedule D, if applicable, for information on investments in DFEson investments in DFEs

Schedule G, if applicable, to report nonSchedule G, if applicable, to report non ‐‐

exempt transactionsexempt transactions

Schedule H for financial informationSchedule H for financial information

EBSA



Large Pension Plan Filing—

What to File, cont.

Schedule R for retirement plan informationSchedule R for retirement plan information

Report of

independent

qualified

public

Report

of

independent

qualified

public

accountantaccountant

Schedule MB if money purchase plan or Schedule MB if money purchase plan or multiemployer plan multiemployer plan

Schedule SB if defined benefit pension plan.Schedule SB if defined benefit pension plan.

EBSA



Basic Attachments

Report of the Independent Qualified Public Report of the Independent Qualified Public AccountantAccountant

For defined benefit pension plans, PDF of For defined benefit pension plans, PDF of manually signed Schedule MB or Schedule SBmanually signed Schedule MB or Schedule SB

EBSA



Only Certain Welfare Plans File

Most large private welfare plans file, but only Most large private welfare plans file, but only certain schedules.certain schedules.

Generally, only those small (under 100) welfare Generally, only those small (under 100) welfare plans funded by a trust or VEBA have to file.plans funded by a trust or VEBA have to file.

EBSA



Welfare Plans that Don’t File

Small welfare plans (those that covered fewer Small welfare plans (those that covered fewer than 100 participants as of the beginning of the than 100 participants as of the beginning of the plan year) that are unfunded, fully insured, or plan year) that are unfunded, fully insured, or a combination of insured and unfunded.a combination of insured and unfunded.

Foreign plansForeign plans

Governmental plansGovernmental plans

Unfunded or insured welfare plans maintained Unfunded or insured welfare plans maintained for a select group of management or highly for a select group of management or highly compensated employees, that meets 29 CFR compensated employees, that meets 29 CFR 2520.1042520.104‐‐2424

EBSA



Welfare Plans that Don’t File,

cont.

Welfare plans that participate in a GIA that Welfare plans that participate in a GIA that files a Form 5500 on behalf of the plan as files a Form 5500 on behalf of the plan as specified in 29 CFR 2520.103specified in 29 CFR 2520.103‐‐2.2.

Church plansChurch plans

Plans maintained solely for (1) an individual or Plans maintained solely for (1) an individual or an individual and his/her spouse or (2) an individual and his/her spouse or (2) partners and partnerspartners and partners ’’

spouses in a spouses in a

partnership.partnership.

EBSA



Large Welfare Plans—What to

File

Plans funded with a trust or VEBAPlans funded with a trust or VEBA

Form 5500(including PDF of manually signed Form 5500(including PDF of manually signed

5500 if using e5500 if using e‐‐signature alternative)signature alternative)


Schedule C for service provider informationSchedule C for service provider information

Schedule D, if applicable, for information on Schedule D, if applicable, for information on investments in DFEsinvestments in DFEs


Schedule H for financial informationSchedule H for financial information

IQPA reportIQPA report

EBSA



Large Welfare Plans—What to

File, cont.

Fully insured/unfunded or combination that Fully insured/unfunded or combination that meet requirements of TR 92meet requirements of TR 92‐‐01 and 29 CFR 01 and 29 CFR 25202520‐‐104104‐‐4444

Form 5500 (including PDF of manually signed Form 5500 (including PDF of manually signed 5500 if using e5500 if using e‐‐signature alternative)signature alternative)



EBSA



Direct Filing Entities (DFEs)

DFE is a trust, account, or other investment DFE is a trust, account, or other investment arrangement in which plans participate, which arrangement in which plans participate, which files its own Form 5500.files its own Form 5500.

Master Trust Investment Accounts must file a Master Trust Investment Accounts must file a Form 5500.Form 5500.

CCTs, PSAs, 103CCTs, PSAs, 103‐‐13IEs, and GIAs may, but are 13IEs, and GIAs may, but are not required to file a Form 5500.not required to file a Form 5500.••

If they file, plans investing in these If they file, plans investing in these arrangements get certain reporting relief.arrangements get certain reporting relief.

••

More information on filing requirements for More information on filing requirements for DFEs in the instructions.DFEs in the instructions.

EBSA



DFVC ProgramDFVC Program

Delinquent Filer VoluntaryDelinquent Filer VoluntaryCompliance ProgramCompliance Program



DFVC Program

Reduced penalties for late/non ‐filed 5500s•

Small Plans = $750/filing or $1500/plan

•

Large Plans = $2000/filing or $4000/plan

IRS will waive their penalties upon

participation in

program

Only Form 5500 filers are eligible

•

No Form 5500‐EZs

•

No Form 5500 SFs

for 2008 or earlier years

EBSA



DFVC Program

Still a 2 Step Program!

Submit original filings electronically•

Only the 2008 may be filed on paper

•

ALL other years must be electronic

Submit to DFVC Program 1 of 2 ways•

Electronically using E‐Pay

•

On paper through the mail

EBSA



Questions

EFAST2 Webcast June 2010 (Final)

Documents

Transcript of EFAST2 Webcast June 2010 (Final)