FAQ 128: EFAST2 DOL Relief - E-Signature for TPAs in DGEM

Problem: Please provide us any guidance once you know what the changes will be in the EFAST2 5500 process.

Solution: TPAs who have obtained their signer credentials as "filing signer" can begin filing the forms for their client immediately in DGEM. TPAs should put the name of the actual Plan's Administrator in the "Plan Administrator" field on the Signer Information section of the Form 5500/5500SF checklist. But the email address field should be the TPA (Preparer)who are providing the UserID and PIN. When inviting signers TPAs will receive the email and they should enter the TPA's UserID and PIN to sign the return. The following instructions are from the DOL on how TPAs can submit the Form 5500/5500SF for their clients: 1) By signing the return for your client, the following legal statement for practitioners authorized to electronically sign the return/report are agreeing to the statement. This new statement will only apply to practioners while the existing jurat language will only apply to plan sponsors, plan administrators, and DFEs. I certify that I have been specifically authorized in writing by the plan administrator/employer, as applicable, to enter my EFAST2 PIN on this return/report in order to electronically submit this return/report. I further certify that: (1) I will retain a copy of the administrator's/employer's specific written authorization in my records; (2)a true and correct pdf copy of the first two pages of the completed Form 5500 or Form 5500-SF return/report bearing the manual signature of the plan administrator/employer under penalty of perjury; (3) I advised the plan administrator/employer that by selecting this electronic signature option the pdf image of that manual signature will be included with the rest of the return/report posted by the Department of Labor (DOL) on the Internet for public disclosure; and (4) I will communicate to the plan administrator/employer any inquiries and information that I receive from EFAST2, DOL, IRS or PBGC regarding this annual return/report. 2) Enter the TPA practioner's User ID and PIN in the Plan Administrator's signature fields of the secure signing page. The Administrator's name should match the name of the actual Plan Administrator that signed the attached Form 5500 or 5500-SF 3) Store the PDF image of the manually signed Form 5500 or 5500-SF in the "Alternative for Electronic Signature" type. That PDF file must contain the Signature page of the Form 5500 or 5500-SF. Do not include a PDF copy of the entire Form 5500 in this PDF file because that may result in the return/report being too large to submit electronically to EFAST2. When scanning the first two pages of the Form 5500/5500SF, the PDF should be scanned in Black and White or Grayscale at no more than 300x300 resolution. The upload does not handle files larger than 4 MB. TPA should NOT affix the plan administrator's PIN to the electronic filing because EFAST2 prohibits individuals from sharing his or her PIN with the person preparing and transmitting the Form 5500 or Form 5500-SF. If the plan administrator is signing the filing, the person authorized to sign as the plan administrator must personally affix his or her own signer credentials. **Important: The information in the Administrator name field on the Form 5500/5500SF must reflect the actual Administrator name and demographic information matching the scanned paper form electronically attached to the filing.