Despite the DOL’s rejection of a previous request by the American Benefit Council for automatic extension of time to file the 2009 Form 5500 until December 31, 2010, the American Society of Pension Professionals and Actuaries (ASPPA) has filed a similar request with the DOL and IRS. With less than two weeks until the filing deadline (October 15, 2010), it seems that many retirement plan sponsors and service providers are struggling to cope with two main issues:
1. Mandatory e-filing using the DOL’s new EFAST2 system. Over time, plan sponsors and service providers will likely learn to embrace the e-filing option. However, the transition year can be a bit ugly with lots of confusion about how to get DOL “signing credentials” and how to use third-party software to submit the filings. Moreover, we are already experiencing some slight delays with EFAST2 accepting filings. Presumably this is because of a heavy influx of submissions as we near the deadline.
2. New Schedule C disclosure requirements. Service providers have been working on this one for a long time, but it is still very complex and getting the required information is not always easy. I expect that it will take a couple of 5500 cycles for the reporting kinks to get worked out.
Regardless, we’ll see if the DOL or IRS consider the filing extension request. It’s not likely, and at this point seems almost too late to do much good.