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Under the Department of Labor's electronic filing regulations, plan administrators are required to keep a paper copy of the filed Form 5500 report, including schedules and attachments, in the plan's records. Recently the DOL clarified that a paper copy of the electronic filing receipt is not sufficient to satisfy this requirement. The paper copy in the records must be a complete copy that is manually signed and dated.
If your company is the plan administrator and the Form 5500 is handled internally, be sure to retain a signed and dated paper copy for your records. If your company uses a third-party administrator to file the Form 5500 report, be sure that this service provider retains a signed and dated paper copy for the plan's records. The plan administrator must make this paper copy available on request to participants, beneficiaries, and the DOL
Also, if your plan is a defined benefit plan and you have an intranet Web site that is used to communicate with employees, you must post certain basic plan identifying and actuarial information from the Form 5500 report on the intranet Web site.
© 2013 Varnum LLP
