EFAST2 Registration Credentials
OMB No. 1210-0117
August 2011
SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT 1995 SUBMISSIONS
A. Justification
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.
Part 1 of Title I of the Employee Retirement Income Security Act of 1974, as amended, (ERISA) requires, under Section 104 of ERISA, that administrators of pension and welfare plans (collectively, employee benefit plans), and employers sponsoring certain fringe benefit plans and other plans of deferred compensation, file returns/reports annually with the Secretary of Labor (the Secretary) concerning the financial condition and operation of the plans. Reporting requirements are satisfied by filing the Form 5500 in accordance with its instructions and the related regulations. Beginning with plan year filings for 2009, Form 5500 filings were processed under a new system, the ERISA Filing Acceptance System 2 (EFAST-2), which is designed to simplify and expedite the receipt and processing of the Form 5500 by relying on Internet-based forms and electronic filing technologies. In order to file electronically, employee benefit plan filing authors, Schedule authors, filing signers, Form 5500 transmitters, and entities developing software to complete and/or transmit the Form 5500 are required to register for EFAST-2 credentials through the EFAST2 website. Requested information includes: applicant type (Filing Author, Filing Signer, Schedule Author, Transmitter, or software developer); mailing address; fax number (optional); e-mail address; company name, contact person; and daytime telephone number. Registrants must also provide an answer to a challenge question (“What is your date of birth?” or “Where is your place of birth?”), which enables users to retrieve forgotten credentials. In addition, registrants must accept a Privacy Agreement; PIN Agreement; and, under penalty of perjury, a Signature Agreement.
2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.
Registration for EFAST2 credentials through the EFAST2 website is the vehicle by which administrators’ and transmitters’ acceptance of Agreements (Privacy, PIN, and Signature) and declarations are transmitted to the Department so they can be provided with secure codes for the signing, filing, and transmission of the Form 5500.
The electronic credentials also provide future verification of a filer’s standing as a qualified participant in the electronic filing program and a means of contact for information exchange and publication distribution between the filer, transmitter, or software developer and the Department. Information from EFAST2 credentials registration may also be used to contact company officials if additional information about the form is needed.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration for using information technology to reduce burden.
The purpose of the EFAST2 program is to electronically collect the Form 5500 from plan administrators and service providers of employee benefit plans. The collection of information included in the registration process is wholly electronic, in keeping with the all-electronic method of filing the Form 5500.
The most recent revision of the Form 5500 distributed by EBSA and the IRS displays information on the first page of the form about the EFAST2 program and how to file electronically.
EBSA hosts or participates in an numerous speaking engagements each year related to updates or changes in filing the Form 5500. Trade association members, accounting firms, and professional societies that attend these meetings are provided with information about electronic filing.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
This application includes only basic identifying information and a signature confirming agreement with the provisions of the electronic filing program. While there is some duplication of identifying information in the registration for EFAST2 credentials and the identifying information ultimately submitted on the Form 5500, which is filed electronically, this duplication is considered necessary in order to establish a secure method of electronic transmission. The Department has limited duplication by designing both the credential registration and the processing system to allow an applicant to apply only once for the required codes, regardless of the number of filings transmitted. The electronic signature and/or codes may be used in subsequent years without re-application.
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.
Not applicable. Because only basic identifying information is required, burden is not expected to differ on the basis of the size of the filer, transmitter, or software developer.
6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
All Form 5500 must be filed electronically. If the information were not conducted or were conducted less frequently, filers would have no way to receive credentials that would allow them to satisfy their statutory obligations to submit the form.
7. Explain any special circumstances that would cause an information collection to be conducted in a manner:
requiring respondents to report information to the agency more often than quarterly;
requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
requiring respondents to submit more than an original and two copies of any document;
requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;
in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;
requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.
No special circumstances.
8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.
Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
This submission has been filed using emergency procedures with a request for approval by August 18, 2011. A notice has been forwarded to the Federal Register providing the public an opportunity through that date. Upon the OMB completing action on this emergency request, a second request for public comments will be made.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No payments or gifts are provided to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
No assurance of confidentiality is made in connection with this information collection.
Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
None.
12. Provide estimates of the hour burden of the collection of information. The statement should:
Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.
If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.
Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.
Based on the most recent data, the Department estimates that 400,000 applications for electronic signatures will be completed on an annual basis. At 20 minutes per respondent for completion of an application, the annual hour burden is 133,333 hours.
The forms are expected to be completed by financial service professions with a wage rate of $65 per hour.1 The equivalent cost of 133,333 hours at this rate is $8.7 million.
Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 or 14).
While it is possible that some service providers may pass on their costs to comply with this information collection, it is assumed for purposes of these estimates, that all respondents will satisfy this requirement using in-house resources. Therefore, there are no operating costs associated with registration for EFAST2 credentials.
14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.
The cost to the Federal government for processing Form EFAST-1 are expected to amount to about $5.00 per form, based on labor hour rates, which would total $41,000.
15. Explain the reasons for any program changes or adjustments reporting in Items 13 or 14 of the OMB Form 83-I.
The increase in the number of responses is due to the fact that all plans most file Form 5500 electronically, which means they have to use the EFAST2 registration process. This increase led to in increase in estimated total hour burden to comply with the information collection, although the burden to obtain EFAST2 credentials is estimated to be the same as it was to apply for EFAST1 credentials. The annual cost burden is eliminated, because the registration is now done exclusively by electronic means; EFAST-1 applications could be mailed, which resulted in material and postage costs.
16. For collections of information whose results will be published, outline plans for tabulation, and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
This is not a collection of information for statistical use and there are no plans to publish the results of this collection.
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
No such authorization is sought..
18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submission," of OMB 83-I.
Not applicable; no exceptions to the certification statement.
B. Collections of Information Employing Statistical Methods
Not applicable. The use of statistical methods is not relevant to this collection of information.
1 EBSA estimates of labor rates include wages, other benefits, and overhead based on the National Occupational Employment Survey (May 2009, Bureau of Labor Statistics) and the Employment Cost Index (October 2010, Bureau of Labor Statistics).
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT 1995 SUBMISSIONS |
| Author | KellyC |
| Last Modified By | Michel Smyth |
| File Modified | 2011-08-10 |
| File Created | 2011-08-10 |