EFAST2
What you need to know now!
Background
You have been hearing about it and now it is here! The 2009 Form 5500 must be filed electronically. In order to file electronically, you must obtain credentials from the Department of Labor even if you already have a user ID and password for EFAST. EFAST2 is a completely separate system from EFAST. This ErisaALERT will address only the credentialing aspects. We anticipate a series of ErisaALERTs dedicated to the Form 5500 in the coming months.
The System
There are basically two approaches to electronic filing; use the government’s IFILE system or use certified third party software. The IFILE system is a no-frills, barebones system built to support small filers with limits on uploads which will not be as user friendly as certified third party software. Ninety per cent of Form 5500 filers use certified third party software; consequently this ErisaALERT will make minimal references to the IFILE system.
The Credentials
Most Plan Sponsors will need a user ID, password and PIN to use EFAST2. Generally, only service providers who transmit the Form 5500 will require an ETIN.
Obtaining the Credentials
To obtain the credentials you must register at www.efast.dol.gov by providing a valid email address. You will receive an email from EFAST2 that provides instructions for completing the registration process.
|
EFAST2 electronic filing credentials |
Uses |
|
User ID (Identification)
|
User IDs are provided for all EFAST2 users who use IFILE to prepare or submit filings. When used in combination with the password, the User ID permits users to access their EFAST2 account and any filing information for which they are responsible. All filing signers, whether using third party software or IFILE, are required to have both a User ID and a PIN. |
|
ETIN (electronic transmitter identification number)
|
An ETIN, along with a PIN, is required to submit filings or batches of filings on behalf of others using EFAST2-approved third-party software. Filing Authors and Filing Signers normally do not need to know the transmitter’s ETIN. |
|
Password
|
When used in combination with the User ID, a password permits users to login to IFILE or the Data Dissemination Service to access their EFAST2 accounts and any filing information for which they are responsible (for example, when the transmitter submits filings and receives acknowledgements). |
|
PIN (personal identification number)
|
The PIN is a unique identifier composed of four (4) numeric characters. A PIN is used when signing a filing, transmitting one or more filings via EFAST2-approved third-party software, or retrieving filing status information. In every case it is used to authenticate a user for the action being performed. |
User Types
When you register for electronic credentials, you select among five user types. You may check as many as apply to you.
- Filing Author – specific to IFILE; if you use certified third party software, DO NOT check this box
- Filing Signer -Filing signers can sign Form 5500/5500-SF filings. Signers include Plan Administrators, Employers/Plan Sponsors, and Direct Filing Entities. No other filing-related work may be done by this user role alone.
- Schedule Author – Schedule authors can complete one or more of the schedules that accompany Form 5500/5500-SF e.g., Schedule B. If you are using EFAST2-approved third party software to author your filing rather than IFILE, 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
What does it mean for most Plan Sponsors?
Decide on your role
Generally, most Plan Sponsors will be a Filing Signer and potentially a Transmitter. Only Plan Sponsors that use IFILE (the government’s software) will be a Filing Author.
In a typical scenario, a Plan Sponsor utilizes a service provider to prepare the Form 5500. The service provider, in turn, presents the completed Form 5500 to the Plan Sponsor for signature and submission. The scenario is similar under EFAST 2; the difference being that the Plan Sponsor will submit the filing electronically. The steps to submit electronically will vary by software provider. It is important to keep in mind that the Plan Sponsor must retain a copy of the Form 5500.
The third party software utilized by your service provider may be set up as the Transmitter in which case you will not have to apply for this role; talk to your service provider!
Decide who will obtain credentials
EFAST2 credentials are signer specific, not company specific. Plan sponsors must decide who will sign the 5500 – the President of the Company, someone from Human Resources or Finance or both?
What should Plan Sponsors being doing now?
- Spend some time and review the information on the DOL website http://www.dol.gov/ebsa/ . The DOL offers a series of recorded EFAST2 webinars. We recommend listening to the webinars.
- Review the FAQ related to EFAST2 on the government website.
- If you want to read more about it, take a look at the EFAST 2 Guide.
- Think about who will obtain the credentials at your organization
- Talk to your service provider who prepares your 5500.
- Register for credentials and make sure you print the page containing your credentials and save it in a safe spot!!
- Stay tuned for subsequent ErisaALERTs on the 5500 filing process!!!
Disclaimer: This material is for the sole purpose of providing general information and does not under any circumstances constitute legal advice and should not be used as a substitute for legal advice. You should seek the advice of counsel when applying the requirements to your plan.
For more information on this ErisaALERT contact us by phone at 610-524-5351 and ask for Mary Andersen or 773-857-1137 and ask for Leanne Fosbre.
To comply with Circular 230 issued by the IRS, we hereby inform you that any tax advice contained in this communication (including attachments and/or enclosures, if any) is not intended or written to be used for the purpose of (i) avoiding penalties that may be imposed under the Internal Revenue Code, or (ii) promoting, marketing or recommending to one or more taxpayers any transaction or matter addressed herein.
