Publication 1004 (8-1986) IDENTIFICATION NUMBERS UNDER ERISA

For federal tax information and forms, call the IRS number listed in your local phone book.

For inquiries about DOL forms, contact your area office of the Pension and Welfare Benefits Administration, DOL.

For inquiries about PBGC forms, contact PBGC at the following address:

 Pension Benefit Guaranty Corporation

 Coverage and Inquiries Branch (25410)

 2020 K Street, N.W.

 Washington, DC 200061806

 (Telephone: (202)778-8800)

Introduction

Three federal agencies have primary responsibility for the administration of the

(ERISA) relating to employee benefit plans. These agencies, the Internal Revenue Service (IRS), the U.S. Department of Labor (DOL), and the Pension Benefit Guaranty Corporation (PBGC), have cooperated in the preparation of this publication.

The publication is written in plain language so that it will be easier to understand. However, the information provided does not cover every situation and is not intended to replace the law or change its meaning.

This publication explains the use of identification numbers on certain reporting forms that employee benefit plans file under ERISA. These forms include: the Form 5300 series, Applications for Determinations (IRS); the Form 5500 series, Annual Return/Report of Employee Benefit Plan (IRS/DOL/PBGC); and the PGBC Form 1, Annual Premium Payment (PGBC). These identification numbers must also be used to identify all DOL required filings, including the summary plan description and summary of material modifications, which are written in a format prescribed by regulation, and on plan termination notices filed with PBGC.

To avoid confusion and delay, and to make sure that a plan is credited with any filings it submits to any of these agencies, please follow the guidlines discussed in this publication. If you use correct identification numbers, your premium payments to PGBC will be credited to the proper account.

Identification Numbers

The following discussions provide information on the kinds of identification numbers you must use for proper filing.

Plan Sponsor's Number

The plan sponsor is:

Plan Administrator's Number

The plan administrator is:

The plan administrator's number is the EIN, which is the nine-digit number assigned to the plan administrator by IRS. The EIN consists of two digits, a hyphen, and seven digits, as follows: 000000000. This is the number used on the plan administrator's quarterly federal tax return that is filed with IRS (IRS Form 941 or 941E). If the plan administrator does not have an EIN, an EIN should be obtained from IRS, as discussed later in this publication.

Plan Number

The plan number is a three-digit number assigned by the plan sponsor to differentiate between plans that are, or may be, established or maintained by the same plan sponsor. A plan sponsor will start numbering the first pension plan at "001," with consecutive numbers for any additional pension plans. Numbering for welfare plans will start at "501" and proceed consecutively. For example, if you, as an employer, have two pension plans (one for salaried employees and one for hourly employees), and a welfare plan for all employees, then the pension plans would be numbered "001" and " 002" and the welfare plan would be "501." It is immaterial whether the salaried or the hourly pension plan, established at the same time, is numbered "001," as long as each has its own number and they are numbered consecutively. Once that number is assigned, you must use the same number consistently to identify the same plan. Failure to use the same number when filing subsequent returns may result in the IRS issuing a delinquent return notice. If a plan is terminated, you must not use its number for any other plan. Instead, use the next available number for any new plan.

Examples

The following examples illustrate how identification numbers are used.

Example 1. The ABC Company Employees Pension Plan is a single-employer plan and has no designated plan administrator. In this situation, the employer is both the plan sponsor and plan administrator. On forms calling for the EIN of the plan sponsor and the plan administrator, the ABC Company should enter the EIN number only on the line for plan sponsor. On the line for plan administrator, the word "Same" should be entered.

Example 2. The DEF Company Employees Pension Plan is a single-employer plan that designates, in the plan document, the XYZ Consultants Company as the plan administrator. On the line for plan sponsor's EIN, the DEF Company should enter the EIN that it used on its IRS Form 941 or 941E. On the line for plan administrator's EIN, the XYZ Consultants Company should enter the EIN that it used on its IRS Form 941 or 941E.

Example 3. A joint labor-management board of trustees is the plan sponsor of a multiemployer plan with the XYZ Consultants Company designated in the plan document as the plan administrator. On the line for plan sponsor's EIN, the joint board should enter the EIN that it used on its IRS Form 941 or 941E. If the joint board does not have an EIN, it must obtain one from IRS. On the line for plan administrator's EIN, the XYZ Consultants Company should enter the EIN that it used on its quarterly federal tax return.

Plan Identification

IRS records are maintained by Employer Identification Number (EIN), Plan Number, Name of Plan Sponsor, and the month in which the plan year ends. Therefore, it is important that each of these items be consistent from year to year when filing the annual return/report.

Notification Letter Number or Letter Serial Number

This is an eight-segment identification number assigned by the IRS to master, prototype, and uniform plans.

The first segment of the eight-segment identification number identifies the legislation with which the plan complies; for example, C indicates compliance with TEFRA, DEFRA, and REA.

The remaining segments identify the key district, the year the notification letter was issued, in what numerical order, and, in some cases, whether it is an initial qualification or an amendment.

Examples

Example 1. The notification letter number C [SPN]3186115 would be assigned to an approved uniform plan submitted by a practitioner to the Cincinnati Key District during 1986 and would be the 115th letter issued during the year.

Example 2. The letter serial number C[SPN]8600130 would be assigned to an approved master or prototype plan submitted to the National Office during 1986. It would be the 13th letter issued, and the final digit, 0, indicates an initial qualification. A last letter of "a" would indicate the first amendment to a previously approved plan.

File Folder Number

The file folder number is a nine digit number assigned by IRS to the case file of an application for a determination letter or opinion letter for internal control and public service purposes. This number appears on all determination and opinion letters issued.

Other Identification Numbers

In the past, both IRS and DOL required other identification numbers on forms relating to employee benefit plans. Although the need for those numbers has not altogether been eliminated, efforts have been made to minimize their use on forms.

For example, IRS issued EINs for fiduciaries of employee pension benefit plans and EINs for the funds (trusts or custodial accounts) associated with those plans. These numbers are not required on forms discussed in this publication, but may be required in certain cases on other IRS forms. If a number is assigned to a trust, this number is not to be used in filing the Form 5500 series returns, except for a wasting trust where the employer/sponsor no longer is responsible for filing.

Correction of Previously Used Numbers

When filing with any of the three agencies for any plan, the plan sponsor's EIN, the plan administrator's EIN, and the plan number must be consistent for all three agencies.

If in the past you have not followed these guidelines, or if you have not used the same EIN or plan number when reporting to all three agencies, at the next filing, you should provide those agencies with the correct number. Along with this number, you should also provide the number you previously used when filing with that agency, so that the necessary corrections may be made. If the form you are filing contains a space for the correction, use it. If it does not, attach a separate sheet to the face of the form, giving the correct number and the number used previously.