Does your Company have an Intranet and a Defined Benefit Pension Plan? If so, read on …

Dennis Purkis, CPA, Audit Manager 

Sponsors of defined benefit pension plans are now required to post information from Form 5500 on their Company Intranet.  If you don’t have an Intranet, you are not required to create one.  But, if you use an Intranet for any type of employee communication, you must comply. 

Required by the Pension Protection Act of 2006, this is effective for the 2008 Form 5500 and all subsequent years. 

Plan sponsors must post basic plan information and actuarial information. To date, no specific regulations have been issued regarding the date information must be posted by and whether notice must be given to employees regarding the information.  However, plan sponsors must comply in the interim until regulations are issued. 

If you need more information, our Employee Benefit Plan Group can help.

EFAST2 Electronic Filing System. If You File on Due Date … It Might Be Late!

Summer Young, CPA, Audit Senior

In the past, employee benefit plans could choose to submit Form 5500 series filings either on paper or electronically using the ERISA Filing Acceptance System (EFAST).  That has changed; think electronic. Beginning January 1, 2010, no paper filings of any kind will be accepted, except for timely filed 2008 plan year filings. Regulation 29 CFR 2520.104a-2 from the Department of Labor (DOL) now requires electronic filing for all filers for plan years beginning on or before January 1, 2009. 

To comply with these regulations and to streamline the ERISA filing process, go to the DOL’s new web-based electronic filing system known as EFAST2.  Please note that EFAST2 is a completely separate system from EFAST. So, even if you are registered with EFAST, you will need to register for and obtain new electronic credentials under EFAST2. 

Now you’re thinking, submitting electronically is a faster method.  How can I be late? You can’t leave your submission to the deadline date, you should submit at least a day in advance. That’s because registration and file submission can take up to 24 hours.  Registering and/or filing on the return/report due date may not be considered a timely submission by the DOL and IRS in 2010. 

Log on to www.efast.dol.gov for more information on EFAST2 where you will find frequently asked questions and an EFAST2 user guide and tutorial. Want to make sure you are on time?  Our Employee Benefit Plan Group will help ensure your reporting needs are met well in advance of the due date!

DOL Scrutiny Increases Timely Remittances. Here’s Proof.

Julie Hiblovic, CPA, Audit Principal

A “hot button” of the Department of Labor (DOL) pertains to regulation 29 CFR 2510. Issued over 10 years ago, it is once again new news. That’s because on January 14, 2010, the DOL amended the Definition of Plan Assets – Participant Contributions regulation. 

The original regulation pertains to all employee benefit plans, regardless of the number of participants and addresses the timely transfer or deposit of employee salary reductions to the Plan’s trust.  It states that salary reductions become plan assets as of “the earliest date on which such contributions can reasonably be segregated from the employer’s general assets”.  The maximum time period for the deposit is the 15^th business day of the month following the month in which the participant contributions are received by the employer. 

The New News

Under this amended regulation, participant contributions to an employee benefit plan with fewer than 100 participants at the beginning of the plan year will be treated as having been made to the plan in accordance with the general rule when contributions are deposited with the plan no later than the 7^th business day following the day on which such amount is received by the employer. 

The DOL has determined not to extend the “safe harbor” provision to cover participant contributions to an employee benefit plan with 100 or more participants at this time. 
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