Form 5500 filers beware! The EFAST2 online filing system is now operational, and it is ready to receive and process Form 5500 filings. All pension and welfare plans that are required to submit an annual return/report on a Form 5500 or Form 5500-SF must do so electronically for plan years beginning on or after January 1, 2009. Beginning January 2010, the all-electronic EFAST2 system started to receive the electronic annual returns/reports. Plan administrators who have not yet done so will need to familiarize themselves with the EFAST2 system. For more information, go to www.efast.dol.gov.

In January, the DOL provided new guidance on how to submit delinquent or amended Form 5500s for plan years prior to 2009 now that the all-electronic system is in place. Beginning January 1, 2010, delinquent and amended filings of Title I plans must be submitted electronically through EFAST2 and may not be submitted on paper. A limited exception is available, however, for delinquent and amended 2008 plan year filings. Specifically, while a plan may submit a delinquent or amended 2008 plan year filing electronically through EFAST2 beginning January 1, 2010, the plan also has the option to submit it through the original EFAST on paper until October 15, 2010, or electronically through June 30, 2010. After October 15, 2010, even 2008 plan year filings must be submitted electronically through EFAST2. For more information, see www.dol.gov/ebsa/faqs/faq-EFAST2.html at Q4.