1/01/2010
We have received several requests for a sample communication that 5500 preparers can send to their customers regarding procedures for obtaining 5500 signing credentials. Below, we will provide some background on the new EFAST2 5500 filing procedures and provide a sample form letter/email that may be sent out by 5500 filing preparers for their customers.
Background on EFAST2 5500 filing procedures
As of January 1, 2010 the Department of Labor (DOL) is going "paper-less" for 5500 filings. All 5500 filings must be submitted to the DOL electronically - DOL has announced no exceptions to this requirement. (Note that the 5500EZ and SSA forms filed with the IRS can be filed via paper and that 2008 filings may be filed on paper through October 15th).
What this means for 5500 software preparers will depend somewhat on what type of software the preparer uses to complete the 5500 forms. Preparers can use a third party software vendor or use the IFILE system with the DOL. The IFILE system is free but does not have many of the features and support that is available with third party software vendors.
No matter what type of software the preparer uses, signers must be registered at the DOL website and must sign the filing electronically. Forms will be signed either at the DOL website or at the third party software vendor's website*. We have provided sample correspondence to explain the procedures for registering with the DOL below.
The EFAST2 registration page is now available:
Procedures for Obtaining Signing Credentials - Sample Correspondence Body
The Department of Labor (DOL) is requiring that all 5500 filings be electronically filed and signed (known as "EFAST 2"). For the first filing year under EFAST 2, signers must register for filing credentials at the DOL website. Below are instructions for how to obtain filing credentials with the DOL.
Once this process is complete, you can continue to use the UserID and PIN provided by the DOL in future years. If a different person signs the 5500 filing in a future year, that person will have to register with the DOL signing credentials at that time. In addition, more than one person may obtain credentials to sign a 5500 form if more than one person may actually sign the filing.
5500 Form Signer Credential Procedures
There are several steps to registering at the DOL website. We suggest that you set aside approximately 15 minutes to complete the process. However, please keep in mind that it may take more than 15 minutes as there are several steps in the process. Please also note that the DOL may change the registration process - these are the steps as we understand them at the time of this email.
- Go to http://www.efast.dol.gov and select the link to register.
- You will be asked to read and sign a privacy statement.
- Complete your profile. You will be taken to a screen where you will be required to complete information that will serve as your profile (name, address, email and user type). Your user type is "filing signer".
- Challenge question. Once your profile information is complete, you will be asked to select a challenge question and answer. This is required and will be used to obtain your UserID and PIN in step 6.
- Confirm email. Check your email and click on the link provided in the email.
- Answer your Challenge Question. You will be asked the challenge question you set up earlier in the process.
- PIN agreement. You will then be asked to sign a PIN Agreement whereby you will agree not to share the PIN that is assigned to you.
- Signature Agreement. You will then be asked to agree to a more detailed "signature agreement".
- UserID and PIN. You will then be provided a UserID and PIN. We strongly suggest printing this page for your records.
- Password. The last step in the process is to create a password that will be assigned to the UserID and PIN that you were just provided. We suggest making a note of the password that you enter for your records. The password can be used with your UserID to obtain your PIN and/or log in to the DOL website in the future to change any profile information if necessary.
Other Considerations
All signers must use the procedure outlined above for obtaining credentials through the DOL website. This requires having access to the internet and email. DOL has not provided a hardship process for plan sponsors without an internet connection / email. You may want to consider including information/resources for your customers if you think the above procedures may be difficult for them to accomplish.
ftwilliam.com 5500 software subscribers will have access to a webpage with detailed registration instructions that will include screenshots. Users can include a link to the detailed instructions in their correspondence. Click here to obtain these detailed instructions.
*Whether signers may use third party software vendor's website for signing will depend on whether that feature is available; ftwilliam.com users may sign the forms at the ftwilliam.com website for no additional charge (preparers may also brand the signing portal to look like their website for no additional charge).
If you have any questions please feel free to contact us at support@ftwilliam.com or call 800.596.0714.