APRIL 2010 Pension Plan tip of the month…

PREPARING AND ATTACHING AN ACCOUNTANT’S OPINION FOR FILING UNDER EFAST2

Under EFAST2, the Department of Labor (DOL) has outlined specific requirements for the Accountant’s Opinion (sometimes called the Audit) performed by an Independent Qualified Public Accountant (IQPA). The Accountant’s Opinion must be printed on letterhead which shows the address of the accounting firm, and must bear a “wet signature,” which is a signature in ink on the printed document. The Accountant’s Opinion must then be scanned into a PDF file (i.e. Adobe Portable Document Format – PDF) to be attached to the annual return. The Accountant’s Opinion must exist as a single PDF attachment, and attached to the Schedule H in the proper location (i.e. to Schedule H, Part III as an attachment of type “Accountants Opinion”).

If the Audit contains any of the following schedules “Schedule of Assets (Held at End of Year),”

“Schedule of Assets (Acquired and Disposed of Within Year),” “5% Transaction Schedule - Schedule of

Reportable Transactions,” or” Schedule of Delinquent Participant Contributions,” they may be included within the audit but must also be broken out into individual PDF files to be attached to the annual return, each in their proper location.

When creating attachments to be included with an EFAST2 annual return, it is highly recommended that attachments be created in black or white format, at 300 dots per inch (dpi) to minimize the size of the files. It is also recommended that no “protection” or “encryption” be placed on these files, as that may prevent the DOL from accepting the PDF as a valid attachment. Please contact this office if you have any question regarding the annual report or the filing thereof.

WHY IS MY FORM 5500 NOW A 5500-SF?

The Pension Protection Act of 2006 created Form 5500-SF, Short Form Annual Return/Report of Small Employee Benefit Plan for plans with 100 or fewer participants. This new form is a simplified version of the annual return filed in prior years, Form 5500. As a simplified form, in most cases it requires no additional schedules to be included (in certain circumstances, a Schedule MB might be included) and is self-contained. Like the Form 5500, the 5500-SF must be filed with the DOL electronically under EFAST2. We have prepared a Form 5500-SF for your plan because it qualifies under the Pension Protection Act to file the less complicated form, or because your one-participant plan is eligible to be filed electronically under EFAST2 using the new Form 5500-SF. If you have any questions please give our office a call.