As part of the Pension Protection Act of 2006 (PPA), plan sponsors of employee benefit plans are required to file their 2009 Form 5500 returns electronically via the DOL/EBSA’s new fully electronic processing system, EFAST2. This is a mandatory requirement for all plan years beginning on or after January 1, 2009.

In order to file your Form 5500 through EFAST2, each plan sponsor must obtain “signer” credentials using the I-REG system (Internet Registration). You must have internet connection and an email address in order to receive these credentials.

So, who needs credentials? The person(s) who sign the Form 5500 on behalf of a plan sponsor or plan administrator must apply for “signer” credentials. If you have filed a Form 5500 in prior years, you will receive a postcard from the DOL regarding applying for these credentials. There are a few things to remember about these credentials.

• Only one set of credentials will be issued for each email address. Signer credentials permit the user to sign as the plan sponsor, the plan administrator or both.
• Typically, a person who signs Form 5500 will require only the filing signer credentials because they will rely on their service provider (Somerset or TPA) to actually prepare and transmit the filing. You may need additional credentials if you will be filing your own Form 5500. If you have other benefit plans that require the Form 5500 that Somerset is not currently providing for you, please contact Susan Hitch for further information.
• The credentials belong to you as an individual, not the business for which you work. Think of the credentials in the same way you think of your social security number–it always belongs to you, no matter where you work.  For this reason, you will want to update your profile whenever your email address changes so that any notification from DOL is delivered to you in a timely fashion.

As of January 1, 2010, you may log into I-REG at www.efast.dol.gov to register for your credentials. There will be a series of input screens for you to act upon, culminating in the assignment of specific electronic credentials, comprised of a User ID and PIN. Please print and save this information for future reference. 

For our clients, Somerset will invite you to an electronic “signing ceremony” where you will input your User ID and PIN into our software, which will allow us to electronically transmit to the DOL/EBSA. You will still be required to keep a paper copy of the signed Form 5500 in your permanent records. You will no longer be able to submit paper Forms 5500 to the DOL/EBSA in Lawrence, Kansas. Somerset will send you a paper or PDF copy of the electronically signed filing. We will receive confirmation from EFAST2 that the filing has been accepted and processed and will keep in our files.

If you have any questions regarding this process, please post a comment here or contact Susan Hitch, Employee Benefit Team and Tax Supervisor.