FAQ and Supplementals

03/26/2025 10:10 am CDT
5330 FAQs
Completing Form 5330 Attachments

5330 FAQs

Table of Contents


Q1: What are the differences between subscription access? (5500 only vs 5330 add on) Top

5500 module subscribers:

  • You can use multiple Form 5330s within the 5500 module.
  • Draft forms are updated for e-filing, including:
    • Updated address fields for the
      • Filer
      • Sponsor
      • Paid Preparer
      • Schedule C Page 5 Line 5b
    • Extra pages for prohibited transactions and Schedule C entries.

5330 Add-On module subscribers, will get additional features, including:

  • The ability to attach documents to individual form filings.
    • 8822-b
    • Amended Return Changes (template provided)
    • Prohibited Transactions Correction Statement
    • Prohibited Transactions No Correction Statement (template provided)
    • Reasonable Cause Explanation
  • The option to lock individual Form 5330s and invite the filer to e-file via the portal.
  • E-filing includes:
    • Submission of Form 5330.
    • Automatic creation and completion of Form 8453-TE (required attachment). The form includes an option to authorize the IRS to withdraw taxes due. If selected, payment info is sent at the time of filing.
  • A status dashboard at the plan level will allow you to track filing details including the pertinent dates, filing status, confirmation number, and the ability to amend filings.


Q2: Do I need the 5500 module to access 5330 e-filing? Top

Yes, a 5500 Module subscription is required to access the 5330 Add-On Module. Only forms created in the 5330 section of the 5500 Module will be available for e-filing. 


Q3: What is the purpose of the additional pages for the Schedule C P4/5? Top

Additional pages were included to capture any transactions on Schedule C that didn’t fit in the available spaces. Since the Modernized e-Filing (MeF) system only permits certain attachments, these entries must be completely included within the form.


Q4: Why is the E-file Status Link disabled?  Top

The E-file Status Link is enabled as soon as the e-filing capabilities are live for that specific filing year. Please Note: the 5330 e-filing options are only available for filing years 2023 and later.


Q4a: I can view the E-File Status dashboard, but can't lock or e-file. Top

The E-file Status dashboard is available to all users, but only those who subscribe to the 5330-Add on module are able to lock filings or submit them for e-file. Please Note: the 5330 e-filing options are only available for filing years 2023 and later.


Q5: If we discontinue access to the 5330 Add-on, will the filing history be lost? Top

Users that cancel their subscription will be able to see the filing status of the completed 5330 forms. 

  • Any forms that were filed electronically will be locked down and users will be unable to make changes.  
  • E-filing will not be available once the module is discontinued. Users will be able to unlock forms that were not e-filed, but after doing so they will remain in an unlocked status and e-filing will be unavailable.


Q6: What is Form 8453-TE? Top

The Form 8453-TE, found in the "Final" column of each Form 5330 filing, serves as a declaration of electronic filing with required signatures and details. This non-editable form auto-populates using information from the Form 5330 and user responses during submission. It is a mandatory attachment for all Form 5330 electronic filings. 

Key Functions Include:

  • Signature Authorization: It provides the electronic signature needed to validate the e-filing of Form 5330.
  • Acknowledgment of Filing: It confirms that the taxpayer has reviewed the form and agrees to its contents.
  • Payment Authorization (if applicable): It ensures that the IRS has permission from the filer to withdraw the excise taxes owed from the specified account on the agreed date.


Q7:What years are available for e-file? Top

E-filing for Form 5330 through ftwilliam.com is available for tax years 2023 and forward. The IRS only accepts e-filed Form 5330 for the three most recent tax years, meaning that as of 1/1/2025, only filings for 2022, 2023, and 2024 will be accepted. If you need to file for 2021 or earlier, you must file on paper, and no waiver is required.  Users must wait for form years to be available in order to e-file (i.e. 2025 PYE filings may not be e-filed until the 2025 forms are available).

On the ftwilliam.com platform, the forms for 2023 and 2024 are specifically coded for those years. While the IRS accepts 2022 filings, our software cannot be used to submit them. Attempting to enter data for prior or subsequent years will result in a rejected or failed submission.


EXAMPLE: A user tries to e-file a  Form 5330 using the 2023 module with the plan year entered as 1/1/2022-12/31/2022. Even though the IRS accepts 2022 filings, upon submission the user will receive a failure notification, as the IRS system detects that TaxYr End(2022) does not match the schema year (2023).


Q7a:What form year should I use for off calendar plan Form 5330 e-filings? Top

When e-filing the Form 5330, the form year is based on the calendar year in which the plan year ends.

Plan Year Start - End Dates   Form Year to Use
2/1/2021 - 1/31/2022 2022*
2/1/2022 - 1/31/2023 2023
2/1/2023 - 1/31/2024 2024
* 2022 e-filing not available on ftwilliam.com

For example, if your plan year ends 12/31/2023, you would file using the 2023 form. If your plan year ends 1/31/2024, you would file using the 2024 form.


Q8: Do my clients need to get an additional credentials to use this service? Top

No, since your client is the filer and authorizes the transmission through the portal, they don’t need extra credentials. Please Note: Only the employer, individual, or other entity who is liable for the tax may file through the portal.


Q9: What happens if a filing is rejected? Top

When a return is rejected, there is a 10-calendar day “Transmission Perfection Period” to fix and resubmit the return electronically. 

This period is solely for correcting errors and does not extend the filing deadline. The 10-calendar day Perfection Period applies regardless of when the return was filed, whether before, on, or after the due date, including any extended due date. The IRS annual system maintenance (cutover period) does not extend the 10-day Perfection Period. This period is never extended.


  • The chart below shows examples of how the IRS determines received dates, assuming:
    • The first rejection occurred on the transmission date.
    • The second rejection occurred on the re-transmission date.
    • Acceptance occurred on the final transmission date.
NOTE: The 10-day Perfection Period is separate from filing deadlines and applies independently of when the return was submitted.  
Tax Year End Due
 Date		 Extension E-Postmark 
 1st reject 		 Original Trans.
  1st Reject
 Date 		 E- Postmark
 2nd Reject		 Postmark 2nd
 Reject 2nd 
 Transmission/
 Reject Date 		 E-Postmark
 Accepted Return 		 Accepted Date/
 Final Transmission		 IRS Received
 Date 
12/31 3/15 No 3/9 3/10 3/10 3/12 3/29 3/30 3/29
12/31 3/15 No 3/9 3/10 3/10 3/12 3/19 3/20 3/9
12/31 3/15 No 3/14 3/15 3/23 3/24 3/24 3/25 3/14
12/31 3/15 No 3/9 3/10 3/15 3/15 4/3 4/4 4/3
12/31 3/15 No 3/9 3/10 3/14 3/15 3/23 3/25 3/14
12/31 3/15 Yes
 9/15		 8/8 8/10 8/10 8/11 9/17 9/18 9/17
3/31 6/15 Yes
 12/15		 8/10 8/10 12/22 12/23 1/9 1/10 1/9
3/31 6/15 Yes
 12/15		 N/A 8/10 N/A 12/23 N/A 12/28 12/23
12/31 3/15 Yes
 9/15		 N/A N/A N/A N/A 9/30 10/1 9/30

* The IRS reviews the Electronic Postmark of the Accepted Return in determining the IRS Received Date.

  • If there is not a rejected return within 10-calendar days of the Electronic Postmark of the Accepted Return, then the IRS Received Date will be the same as the postmark.
  • If there is a rejected return within 10-calendar days of the Electronic Postmark of the Accepted Return, the IRS Received Date will be the earliest reject date within that 10-day period.

Explanation Example from chart: 

  • Row 1: The Electronic Return Postmark Accepted Return date shows 3/29. As the last rejected electronic postmark was 3/10, this falls outside of the 10-calendar day period, thus the IRS Received Date is recorded as 3/29.
  • Row 2: The Electronic Return Postmark Accepted Return date shows 3/19. The earliest rejected electronic postmark that falls within the 10-calendar day period is 3/9. As such, the IRS received date is 3/9.
NOTE: Corrections must be submitted in the same format as their original filings.  If the taxpayer is required to file their original return electronically, then they must also e-File their amended returns. A taxpayer must receive an approved waiver to file those tax years on paper. Information about requesting a waiver can be obtained by contacting the MeF Helpdesk at 1- 866-255-0654 or at IRS.gov.

Q9a:  Known MeF Rejection Errors, Section B and Section E Top

There is a known issue with the MeF system when e-filing Section B or Section E as outlined below.

  • Section B. Taxes that are reported by the 15th day of the 10th month after the last day of the plan year.

Section B,  reviews entries in Schedule D, Schedule E, Schedule F, and Schedule L.

When the submission includes entries for  Schedule F, Line 1c, the value reported should be the greater of Line 1a or Line 1b multiplied by 5%.  (As shown in the example below, Line 1b ($200), is greater than line 1a ($100). Line 1b $200*5%= $10)

A close up of a textAI-generated content may be incorrect.

While the system correctly calculates the value on Line 1c, the IRS response shows the filing as Rejected with the following error message:

Error: If ‘FailureMeetRqrEndngrCrtclTxGrp’ in Form 5330. Schedule F has a value,  then ‘FailureMeetRqrPlnEndngrCrtclTxAmt’
must have a non-zero value equal to the greater of  (‘ContriMeetBenchmarkOrRqrAmt’ and ‘AccumulatedFundingDefnAmt).


The IRS is aware of this issue and is working on a correction to suppress the error message and allow the filing.  As of Feb. 2025, the filings are still being rejected. These will need to be paper filed until the IRS updates their software. 


  •  Section E. Tax that is reported by the last day of the month following the month in which the failure occurred.

Section E requires users to complete Schedule J, where the fee is calculated by multiplying the number of failures listed on Schedule J, Line 4, by $100. (As shown in the example below, Line 4, 30 failures * $100= $3,000.00)

While the system correctly calculates the value on Line 5, the IRS response shows the filing as Rejected with the following error message:

Error: If Form 5330, Schedule J, 'FailProvideNtcRedFutAccrTaxAmt' has a value, 
then it must be equal to 'TotERISASect204hNtcFailureCnt' multiplied by 100.

The IRS is aware of this issue and is working on a correction to suppress the error message and allow the filing.  As of Feb. 2025, the filings are still being rejected. These will need to be paper filed until the IRS updates their software. 


Q10: Do filers have to physically print and sign the Form 5330? Top

Filers are required to retain copy of the Form 5330 for their records, but a copy of a manually signed 5330 does not need to accompany the filing. For subsequent steps to be completed in the Portal, the filer must first select the Print 5330 button.


Q11: Do filers have to physically print and sign the Form 8453-TE? Top

Filers must include a signed Form 8453-TE with each filing. This can be done using a digital/electronic signature or by printing and wet signing the form and uploading it as a PDF within the signing process. For details on digital/electronic signatures, refer to IRS Electronic Signature Program (Section 10.10.1.6.2 and Exhibit 10.10.1-2).


Q11a: Does the 8453-TE signer need to be the same individual as the 5330 filer? What should be done if the Officer is different from the person responsible for the tax? Top

The filer listed on Form 5330 does not have to be the same person as the officer listed on Form 8453-TE.

  • Form 5330: The filer on Form 5330 is typically the person or entity responsible for filing the form, which could be the organization itself or a tax professional.
  • Form 8453-TE: The individual who signs the 8453-TE must be either the person responsible for the tax or an officer of the tax-exempt entity. 
    • If signing as an Officer, that person must be someone who has the authority to sign on behalf of the organization (like the president, vice president, or treasurer). 
    • Again, the signer does NOT have to be the same person who is listed as the filer on Form 5330.

  The distinction is made in Part II paragraph 3 on the 8453-TE by selecting the appliable check box:


Q11b: Does Part III of the Form 8453-TE need to be completed by the Paid Preparer (or ERO)? Top

No, when using the ftwilliam.com software and filing Form 5330 through the portal, Part III of Form 8453-TE does not need to be completed by the ERO or the paid preparer. Even if a paid preparer or ERO helped prepare the form, the actual filer is the one submitting it electronically, so this section does not apply.


Q12: Do clients have to provide banking information? Top

Filers have the option to not submit payment with their filing. If they choose this option, they must contact the IRS directly to make the payment. Currently, we do not have guidance on where payments should be sent if not submitted during e-filing.


Q13: Is banking information stored? Top

Banking information is not stored. After a filing is submitted, payment details are deleted, leaving only a Yes or No indicator of whether payment information was sent. Filers are encouraged to carefully verify banking details before submitting.


Q14: Will Batch processing be available? Top

 In the second release phase (TBD) users will be able to batch edit check, lock, and invite portal users to e-file as well as review the status of filings within the batch. More details to come.  


Q15: Can I file on behalf of my client through the portal? Top

Only the employer, individual, or other entity who is liable for the tax may file the 5330 through the portal. Please see Q16/17 pertaining to filing on behalf of clients.


Q16: Will we be able to file on behalf of clients in the future? Top

We anticipate in our second release phase (TBD) there will be an option to file on behalf of a client. This functionality will be similar to the 5500 module sign on behalf of feature. More details to come.


Q17: Are additional credentials needed to file on behalf of clients? Top

Yes, all electronic filers filing on behalf of clients, must register as an Electronic Return Originator (ERO). Once e-filing outside of the portal is available, registered EROs can use ftwilliam.com to file Form 5330 for their clients. To streamline your experience, we recommend registering for credentials at your earliest convenience. 

 Please note that the application process may take up to 45 days for approval.

 The IRS outlines this process in 3 steps:

We have also included a detailed tutorial on the application process: Creating Your Application to Become an Authorized IRS e-file provider.pdf

Q18: What time zone is used when the IRS reviews submissions for timeliness? Top

The IRS Received Date is initially set by the electronic postmark in the Transmitter’s time zone (Central Time for ftwilliam.com). If there’s a question about timeliness and the Transmitter is in a different time zone, the taxpayer’s time zone will determine the received date.



Completing Form 5330 Attachments

When filing Form 5330, you may need to include one or more of the following attachments, each with its own specific formatting and content requirements:

  • 8822-B
  • Amended Return Changes (template provided)
  • Prohibited Transactions Correction Statement
  • Prohibited Transactions No Correction Statement (template provided)
  • Reasonable Cause Explanation

Below is a detailed explanation of each attachment type and its requirements.

8822-B: Change of Address or Responsible Party
  • Format: Completed PDF form.
  • Instructions:
    • Download and fill out IRS Form 8822-B.
    • Save the form as a PDF.
    • Attach the completed PDF to the filing.
Amended Return Changes

Select the Amended Return Changes attachment type from the dropdown menu:

 

Once selected, a link to the .csv template will populate:

To meet IRS requirements, every column in the provided spreadsheet must be completed.

  • Do not modify or remove the header row or any content in rows 1–11, as this will prevent the file from importing properly.

Column A: PartNum

  • Identify whether the correction applies to Part I or Part II of Form 5330.
  • If a correction affects both Part I and Part II, create separate line items for each.
  • Use the following codes:
    • I → Part I (Lines 1–16)
    • II → Part II (Lines 17–19)
  • Note: You do not need to document changes to specific schedules listed on pages 3–6 of Form 5330.

Column B: LineNum

  • Enter the specific line number from Form 5330 being corrected.

Column C: OnPreviousReturnAmt

  • Input the original value from the previous return for the line identified in Column B.

Column D: OnAmendedReturnAmt

  • Enter the corrected value that will appear on the amended return.

Column E: ExplanationTxt

  • Provide a brief, clear explanation for the correction.



Reasonable Cause Explanation
  • Format: Typed directly into the attachment window.
  • Instructions:
    • The software automatically converts the text into the required XML format.
    • Provide a clear, concise explanation of the reasonable cause for the late or incorrect filing.
  • Example:


Prohibited Transactions Correction Statement

Purpose:

  • Used when you have corrected one or more prohibited transactions reported on Schedule C of Form 5330.
  • Provides details on the correction, including the date it was made, the method used, and the excise tax paid.
  • Upload the statement as a PDF file.

Required Information:

  • Transaction Number: From Schedule C, column (a).
  • Description: Brief summary of the transaction.
  • Correction Date: When the transaction was corrected.
  • Correction Method: How the correction was made (e.g., lost earnings deposited, re-amortization of loans, etc.).
  • Excise Tax Paid: The amount paid due to the transaction.

When to Use:

  • When the prohibited transaction has been corrected and you need to report the correction to the IRS.

Example:

Plan Name: ABC Company 401(k) Plan
EIN: 12-3456789
Plan Year: 2024

Transaction 1:

  • Transaction Number: 001
  • Description: Late deposit of employee deferrals from January 2024 payroll.
  • Correction Date: 03/15/2025
  • Correction Method:
    • The employer deposited the missing deferrals into affected participants' accounts.
    • Lost earnings were calculated using the Voluntary Fiduciary Correction Program (VFCP) calculator and credited accordingly.
    • Affected participants were notified of the correction.
  • Excise Tax Paid: $2,000

 Transaction 2:

  • Transaction Number: 002
  • Description: Incorrect loan offset distribution.
  • Correction Date: 04/01/2025
  • Correction Method:
    • The loan was re-amortized to correct the offset error.
    • The excess offset amount was restored to the participant's account, including lost earnings.
  • Excise Tax Paid: $1,500


Prohibited Transactions No Correction Statement – Instructions

To complete the spreadsheet, list each unresolved prohibited transaction from Schedule C, including:

  • A brief description of the transaction.
  • The planned correction date, which Schedule C does not capture.

 Column A: TransactionNum

  • Enter the transaction number from Schedule C, column (a).
  • Use a whole number with up to 3 digits. 
  • Example: 001
NOTE: Excel may automatically remove leading zeros. Therefore, 001 may appear as 1 in the spreadsheet.

Column B: TransactionDesc

  • Provide a brief description of the transaction, expanding on what is reported in Schedule C.
  • Example:
    • “Late deposit of employee deferrals from January 2024 payroll.”

Column C: PlannedCorrectionDt

  • Enter the date you plan to make the correction.
  • Use the standard MM/DD/YYYY format (up to 10 characters).
  • Example: 03/15/2025
TransactionNum
TransactionDesc
PlannedCorrectionDt
1
Late Deposit of January 2024 deferrals
3/15/2025
2
Incorrect loan offset distribution
4/01/2025

Key Differences between Prohibited Transactions Correction Statement and Prohibited Transactions No Correction Statement


Feature
Correction Statement 
No Correction Statement
Purpose / When to Use
Used to report corrected prohibited transactions. Required when a prohibited transaction has been corrected and needs to be reported to the IRS.
Used to report unresolved prohibited transactions with a planned correction. Required when no correction has been made yet.
Required Attachment Type
PDF file (customer generated)
Spreadsheet (template provided)
Details IncludedIncludes detailed correction info: 
1. Transaction Number from Schedule C 
2. Description of the transaction 
3. Correction Date (MM/DD/YYYY) 
4. Correction Method (e.g., lost earnings, re-amortization, etc.) 
5. Excise Tax Paid		Includes unresolved transaction details: 
1. Transaction Number from Schedule C 
2. Description of the unresolved transaction 
3. Planned Correction Date (MM/DD/YYYY)

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