EFAST2 Is Coming

What is E-FAST2?

Beginning in 2010, the DOL will require that all Form 5500s be filed electronically through EFAST2. EFAST2 is short for electronic filing acceptance system part 2. It is an online system for submitting Form 5500s to the Department of Labor (DOL).

What changes will this bring for plan sponsors?

BPC will continue to prepare your Form 5500 as usual. However, you will notice the following changes in the forms and in our procedures:

• Paper filings will no longer be accepted, except for the Form 5500-EZ used by one participant filers
• Many small plans exempt from the audit requirement will now have the option of filing on the Form 5500-SF, which is a shorter form with no schedules
• Plan sponsors will need internet access and a valid e-mail address
• Individuals responsible for signing the Form 5500 will need to obtain “filing signer” credentials through the DOL website
• You will be invited via e-mail to a “signing ceremony” where you will login to our website with your pre-approved credentials in order to electronically sign the forms.
• We expect heavy use of the system at filing deadlines. Due to uncertainty of the system’s ability to process the anticipated level of high usage around deadlines, we strongly encourage all forms be filed a minimum of 2-3 weeks prior to your filing deadline
• Plans subject to the audit requirements will need to have their audits performed earlier in order to ensure the forms and audit are filed timely
• Plan sponsors will be required to retain a paper copy of the forms with a wet signature for their records as they always have in addition to the electronic processing. The paper forms will no longer have a bar code at the bottom.
• ERISA 403(b) plans will also be subject to all of the above filing requirements

When will this change happen?

The EFAST2 system is expected to go live on January 1, 2010. All 2009 calendar year plans will be required to file using EFAST2. Any non-calendar year plans that have not filed by December 31, 2009, will need to file using EFAST2.

BPC wants to ensure these changes are as easy as possible for our clients. Over the course of the next few months, we will continue to communicate with you regarding the new filing requirements. We understand for some clients the new technological requirements may seem like a great burden. However, we will strive to make the process as easy as possible and will be available to walk you through the process.

Please watch for future communications from BPC regarding EFAST2.