Employee Benefit Plan Audit Quality Center

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Employee Benefit Plan Audit Quality Center

DOL EFAST 2 Electronic Processing for 2009 Form 5500 Live Forum

March 3, 2010 

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Today’s Speakers

Marilee Lau, Chair EBP Audit Quality Center

Riquita Quarterman, US Department of Labor

Sue Peirce, Apple Growth Partners

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DOL EFAST 2 Electronic Processing for 2009 Form 5500 Live Forum

A L L F I L E

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Introduction

Marilee LauChair EBP Audit

Quality Center

Objectives

• Provide an overview of the new electronic processing EFAST 2 system

• Address how it will affect your plan clients• Discuss implications to EBP auditors• Q & A session: send questions to

ebpaqc@aicpa.org

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DOL EFAST 2 Electronic Processing for 2009 Form 5500 Live Forum

First Polling Question

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Overview of the New Electronic Processing EFAST 2 System

Riquita Quarterman

U.S. Department of Labor

Overview

Basics of Using EFAST2Basics of Using EFAST2 Primary Resource – Primary Resource –

www.efast.dol.gov/fip/forms_pubs.htmlwww.efast.dol.gov/fip/forms_pubs.html

Review of Key Changes to the 2009 Annual Review of Key Changes to the 2009 Annual Return/Report – What You Need to KnowReturn/Report – What You Need to Know

Delinquent Filer Voluntary Compliance Delinquent Filer Voluntary Compliance ProgramProgram

Electronic Filing Mandate

All Form 5500 and Form 5500-SF must be All Form 5500 and Form 5500-SF must be submitted through EFAST2 except filings submitted through EFAST2 except filings which have a plan year begin date in 2008 which have a plan year begin date in 2008 may be submitted on paper through EFAST.may be submitted on paper through EFAST.

This includes plan year 2007 and prior This includes plan year 2007 and prior returns/reports. See EFAST2 FAQ #4.returns/reports. See EFAST2 FAQ #4. www.efast.dol.gov/faq/faq_efast.htmlwww.efast.dol.gov/faq/faq_efast.html

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EFAST2 FAQ #4EFAST2 FAQ #4

EFAST 2 FAQs can be found at:http://www.dol.gov/ebsa/faqs/faq-EFAST2.html

Q4: How can I submit a delinquent or amended Form 5500 return/report for a Title I plan for years prior to 2009 once the EFAST2 system is available?

Two ways to create & submit filings:Two ways to create & submit filings:• 3rd Party Certified Software• IFILE (free web-based filing application)

Combinations OKCombinations OK List of approved third party software is posted List of approved third party software is posted

on DOL website www.efast.dol.govon DOL website www.efast.dol.gov

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Electronic Filing with EFAST2

EFAST2 Help

EFAST2 website at www.efast.dol.gov• FAQs• Users guides• Web-based tutorial

Staffed help desk at 1-866-GO-EFAST during business hours

Third party software certification & support

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Using EFAST2

Register for credentials Create a filing Check the filing for errors Sign the filing Submit the filing and check the status View filings on our website Not every screen is shown in this presentation

Third party software mostly used and will differ iFile tutorial walks you through the screens

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Register for Credentials

All plan sponsors & administrators must register for credentials to sign filings (Filing Signer role)

Anyone wishing to fill out the forms/schedules through iFile must register for credentials to author (Filing Author or Schedule Author role)

Anyone wishing to transmit completed filings through third party software MAY need to register for credentials (Transmitter role)

Actuaries and accountants do not need to register but may do so if they wish

You can not use EFAST ELF credentials for EFAST2

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Summary of Steps to Register

Go to www.efast.dol.gov and click “Register” Enter contact information and select role Follow the screens Check your email (and spam folder) for a

message from EFAST2 Click on the link in the EFAST2 message to

complete your registration Keep track of your UserID and password

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Register – 1st Screen

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Register – 2nd Screen

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Register – 2nd Screen Continued

Register – 3rd Screen

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Register - Email

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Register – Verification

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Register – PIN Agreement

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Register – Signature Agreement

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Register - Final

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Registration Tips

Use your business email address when registering, rather than your personal address.

Check your spam folder if you do not receive the EFAST2 email within 5 minutes.

You can change your addresses (including email), phone number, PIN, Password, and roles at any time. Just login to the website and click “User Profile”.

You can not modify the UserID or secret knowledge (place or date of birth). This may change in the future.

Your Personal Identification Number (PIN) is personal and not to be shared.

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DOL EFAST 2 Electronic Processing for 2009 Form 5500 Live Forum

A L L 5 5 0 0

Create a Filing

IFILE is a free, optional, ‘no-frills’ web based filing application available on the EFAST website

Approved third party software should provide filers with added value

Must obtain “Filing Author” credentials before creating a filing in IFILE

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Create a Filing – Form 5500

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IFILE Workspace

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Add Attachment

Validating a Filing – List of Errors

Signatures can be applied through Signatures can be applied through approved third party software or IFILE.approved third party software or IFILE.

Needed signatures are specified in Form Needed signatures are specified in Form 5500 and 5500-SF instructions.5500 and 5500-SF instructions.

Signatures in EFAST2 mean UserID and Signatures in EFAST2 mean UserID and PIN.PIN.

One process for signing filings in iFile; One process for signing filings in iFile; one size fits all.one size fits all.

Sign the Filing

Summary of Steps to Sign a Filing in IFILE

Associate SignersAssociate Signers• Open/Import a filing in iFile• Click associate signers• Enter one or more registered filing

signer’s email address

Apply SignatureApply Signature• Signer opens the filing in iFile and reviews

the filing• Click sign filing• Enter User ID & PIN and select signature

line

Sign the Filing

Associating a Signer

Specifying Registered Signer(s)

Signer(s) E-mail Notification

Signature Legal Language

Application of Signature

Individuals must have registered as signers Individuals must have registered as signers before you can associate them to a filing and before you can associate them to a filing and email address must match in IFILE.email address must match in IFILE.

If a required signature is missing you will receive If a required signature is missing you will receive a message AFTER you submit the filing – it won’t a message AFTER you submit the filing – it won’t show up in the Validation check before you show up in the Validation check before you submit.submit.

Signature Tips

Signature Tips

If the plan administrator signature is missing If the plan administrator signature is missing or incorrect, you will get a “STOP” message or incorrect, you will get a “STOP” message when you submit your filing.when you submit your filing.

If plan administrator is same as plan If plan administrator is same as plan sponsor, that person only needs to register sponsor, that person only needs to register once and apply their signature to the plan once and apply their signature to the plan administrator “line”.administrator “line”.

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DOL EFAST 2 Electronic Processing for 2009 Form 5500 Live Forum

Second Polling Question

Submitting a Filing

EFAST2 automatically receives and tests filing submissions. 100MB is the current file size limit.

Filers will see an initial list of errors/warnings if they validate before submission.

Filers should receive an acknowledgment ID after submitting.

Filers must check the status of their filing and final errors/warnings after receiving the acknowledgement ID.

Submitting a Filing

Filing status that includes the word “unprocessable” means we did not receive a filing from you. See EFAST2 FAQ #38.

In IFILE, only the author can submit filings.

Open the signed filing in iFile. Click Submit. Click OK in the Acknowledgement popup

window. In the left hand navigation bar, click

Submissions. See the Status of the filing you submitted

(click if possible) to ensure EFAST2 received and could process what you sent.

Summary of Steps to Submit a Filing in IFILE

Check the filing status and list of errors after you submit (may differ from the pre-validation you did before you submitted).

If you are amending or want to make a copy of a filing, use the “amend” button in the submission list window.

Submitting Filing Tips

Viewing Submitted Filings

Generally, filings received in EFAST2 are disclosed on our website within 1 day of receipt.

This includes Form 5500-SF.

Filings not disclosed through the EFAST2 website are available through EBSA’s public disclosure room.

Go to www.efast.dol.gov and click “Search for Filing(s)”

Filing Search Screen

Viewing a Specific Filing

General Consideration when Using EFAST

It’s a first-year Internet-based web application, it’s not bullet-proof.

•If your Internet connection is fast, you will have a better experience.•If you click something and it doesn’t do what you expect or your screen freezes, close your browser and try it again.

Where to Go For Help

Don’t get frustrated, help is available. • Use the information and guides on our

website. • Call the help desk (1-866-463-3278) 8:00

a.m. to 8:00 p.m., Eastern Time, Monday through Friday, except for federal holidays.

No EFAST CorrespondenceUnder New System

Filers and service providers/submitters should pay close attention to the EFAST2 automatically generated list of errors/warnings.

Filers will no longer receive post-filing written correspondence from EFAST requesting voluntary corrections of errors/incomplete filings within 30 days.

DFVC Program

DFVCP will still be available with shift to EFAST2

DFVCP now accepts electronic payments Still a two-step process:

• 5500 filing with EFAST (electronic after 1/1/2010)

• Complete online calculator at www.efast.dol.gov then select Pay Online

• Nothing to send to NC if paying electronically

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DOL EFAST 2 Electronic Processing for 2009 Form 5500 Live Forum

A L L E F A S

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Auditor’s Considerations

Sue PeirceApple Growth

Partners

Working Together Via EFAST2

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Signer Auditor

Preparer

Form 5500

Workflow

• START early

• Highly dependent upon third party software– Three options

• Private Desktop• Labor Department Web-Based IFILE• Private Web-based

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Third Party Web Based

• Preparer has 3 options for filing:– Export XML file and upload to IFILE

• TPA must invite client to sign Form 5500 on IFILE and submit to DOL

• TPA sends email to client notifying that filing is ready for signature. Client logs onto portal and signs.

• Employer may sign and directly transmit via their web-based software

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Sample Web Portal

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Uploading Attachments

Sample Attachment Options

PINs May Not Be Shared 11/9/09

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Subsequent Events Requirements Under EFAST 2

• ASC 855-10-25-2– An entity that has a current expectation of widely

distributing its financial statements to its shareholders and other financial statement users (including a public entity) shall evaluate subsequent events through the date that the financial statements are issued. All other entities shall evaluate subsequent events through the date that the financial statements are available to be issued.

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Subsequent Events Requirements Under EFAST 2

• At its February 20, 2010 Meeting:– The Board decided to clarify which entities are required to evaluate

subsequent events through the date the financial statements are issued as either: An entity that files or furnishes financial statements with the SEC (or another regulator if such filing satisfies the SEC’s requirements); or

– An entity that is a conduit bond obligor for conduit debt securities that are traded in a public market.

– Other entities (including employee benefit plans) will evaluate subsequent events through the date the financial statements are available to be issued.

– The Board directed the staff to draft a final Accounting Standards Update for vote by written ballot.

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DOL EFAST 2 Electronic Processing for 2009 Form 5500 Live Forum

Third Polling Question

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Question & Answer Session

Submit questions to the

EBPAQC mailbox at ebpaqc@aicpa.org

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DOL EFAST 2 Electronic Processing for 2009 Form 5500 Live Forum

A L L P I N S

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Question & Answer Session

Submit questions to the

EBPAQC mailbox at ebpaqc@aicpa.org

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DOL EFAST 2 Electronic Processing for 2009 Form 5500 Live Forum

Fourth Polling Question

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Coming Events – EBPAQC Member Only Webinars

• 11-K Audit Live Forum, March 23, 1:00 – 3:00 pm ET

• ESOPs Live Forum, April 20, 1:00 – 3:00 pm ET

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AICPA Resources

• 2010 AICPA Audit & Accounting Guide, Employee Benefit Plans – to be available in May 2010

• 2010 Audit Risk Alert for Employee Benefit Plans – to be available in May 2010

• AICPA Annual Webcast on Employee Benefit Plans Strategic Briefing, to take place in late April or Early May 2010

• AICPA National Conference on Employee Benefit Plans, Las Vegas, NV, May 11 – 13, 2010

• AICPA Employee Benefit Plan Audit Workshop for Defined Benefit and Defined Contribution Plans, March 29 – 30, 2010, Chicago, Illinois; July 26 – 27, 2010, New York, New York

• AICPA Annual Employee Benefit Plans Accounting, Auditing and Regulatory Update Conference, Washington, DC, December 13 – 14, 2010

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Employee Benefit Plan Audit Quality Center

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