1. Should late filings be sent to IRS or to the EFAST center in Kansas?

Late filings for any plan year should always be sent to the EFAST center in Lawrence, Kansas. Form 5500 filings for any plan years are no longer processed by IRS.

2. Must a reasonable cause explanation be attached to a late filing?

It is prudent to include an explanation for the reason the filing is being submitted to the agency past the original due date. IRS has traditionally worked with plan sponsors and practitioners to avoid late filing penalties when there is a valid business reason for the late filing. Also check the box at Line D of Form 5500.

The DOL has a delinquent filer program. Check the DOL's website for more information about presenting late filings of Form 5500 to DOL.