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CCH® PENSION — 01/24/12

IRS gives tips for fixing problems with electronic signatures for Form 5500s

A plan sponsor/employer or the plan administrator must electronically sign Forms 5500 and 5500-SF before submitting the returns. The forms may be signed by an authorized plan service provider using the additional "e-signature option." The electronic filing system will reject forms not properly signed, potentially resulting in penalties for the plan. In the latest issue of Employee Plans News, the IRS has described the process for validly e-signing Forms 5500 and 5500-SF and the steps to take in fixing problems with these electronic signatures.

Starting January 1, 2012, Forms 5500 and 5500-SF that have no electronic signature will receive a filing status of "unprocessable" and Forms 5500 and 5500-SF that have an invalid electronic signature will receive a filing status of "processing stopped."

Valid e-signature

Any individual who e-signs an original or amended return must have a valid EFAST2 User ID and PIN. A person may need to register and obtain new or modified EFAST2 credentials if an electronic signature is rejected by the online filing system. The IRS notes that authorized service providers e-signing new or amended forms must:

• have specific written authorization from the plan administrator,
• have the plan administrator manually sign a paper copy of the completed new or amended form, and
• attach a PDF copy of the first two pages of the manually signed new or amended form to the filing (the DOL will include the image of the manual signature in their online database.)

Filing status

After submitting the form, the "filing status" should be checked for error messages. The IRS says that if the filing status is "Unprocessable" and the filing didn't have an electronic signature, the individual should electronically sign and re-submit the original filing. If the filing status is "Processing Stopped" and the filed form had an invalid electronic signature, the individual should electronically sign and submit an amended filing.

Source: IRS Employee Plans News, Issue No. 2011-9, December 20, 2011.

For more information, visit http://www.wolterskluwerlb.com/rbcs.

For more information on this and related topics, consult the CCH Pension Plan Guide, CCH Employee Benefits Management, and Spencer's Benefits Reports.

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