Enrolled Retirement Plan Agent Frequently Asked Questions
1. What is an ERPA?
An ERPA is an Employee Retirement Plan Agent. ERPAs are retirement plan professionals that can represent clients before the IRS with respect to IRS Forms 5300 and 5500 series and who are not otherwise included in a category of individuals allowed to practice before the IRS.
2. Do ERPAs need a Preparer Tax Identification Number (PTIN)?
Enrolled Retirement Plan Agents are only required to obtain a PTIN if they:
- prepare, or
- assist in the preparation of,
all or substantially all of any tax return or claim for refund that is not on the list of forms exempt from the PTIN requirement.
ERPAs that prepare only Form 5300 or 5500 series returns aren't required to obtain a PTIN. If, during the course of your work, you encounter a situation which would require you to prepare, for compensation, Form 5330 for excise taxes due, then YES, you are required to obtain a PTIN and renew it annually. If you prepare any tax return, such as 5330, 990T or 1041, that is not specifically exempt, you are required to have a PTIN.
If you never anticipate preparing any tax return for compensation, you probably don't need a PTIN. For example, if you work exclusively in the determination arena and only prepare Forms 5300, 5307 and 5310, chances are, you won't need a PTIN. Likewise, if you only perform plan administration and prepare Forms 5500 you aren't required to obtain a PTIN.
However, there are advantages to having a PTIN. All IRS Continuing Education providers are required to register their programs electronically. This includes ERPA CE providers. Circular 230 contains record keeping requirements for CE credits by both you and the approved CE provider. If you have a PTIN and report it to your provider upon successfully completing a CE program, your CE provider can report your CE credits electronically. You can then access your listing of credits using your PTIN. This helps keep track of your annual CE requirements and reporting requirements on Form 8554-EP, Application for Renewal of Enrollment to Practice before the Internal Revenue Service as an Enrolled Retirement Plan Agent (ERPA).
3. Where can I find an ERPA?
View a list of ERPAs:
1. Which programs qualify for ERPA CE credits?
You must obtain CE credits from an IRS approved continuing education provider. View the list of approved providers.
2. I applied during an enrollment cycle, how many continuing education credits must I complete?
If your initial enrollment occurs during an enrollment cycle, you're required to complete 2 hours of qualifying continued education credits per month AND 2 hours of ethics or professional conduct credits per year. When your new enrollment cycle begins, you will be required to satisfy the full 72-hour continuing education credit requirement.
Example: If you enroll in year 2 of an enrollment cycle in May, you are required to complete 2 hours of qualifying education credits for each month (May (2), June (2), July (2), August (2)…etc. until the end of the enrollment year(s); in addition to completing 2 hours of ethics or professional conduct credits for each year. Your result would be, 40 hours of CE credits with 4 hours of ethics credits for the enrollment cycle.
3. I enrolled in year 3 of an enrollment cycle in the month of November and my social security number ends with a five (5). How many CPE credits must I complete?
You are required to complete four (4) CE credits for November and December of the 3rd year; of which two (2) must be completed in Ethics courses. Your next renewal cycle 2014-2017 you will be required to complete a minimum of 72-hours of continuing education credits which encompasses three (3) calendar years. (Note: a minimum of 16 hours of continuing education credits, of which 2 credits must be on ethics, must be completed during each enrollment year of an enrollment cycle.)
4. I enrolled in year 2 of an enrollment cycle in the month of March and my social security number ends with a seven (7). How many CE credits must I complete?
Due to the month and year that you enrolled, you are required to complete 44 CPE credits before December 31, 2014. Your next renewal cycle beginning 2015-2018, you will be required to complete a minimum of 72 hours of continuing education credits.
5. I enrolled in January of year 1 of an enrollment cycle and my social security number ends with a one (1). How many CE credits must I complete?
Due to the month and year that you enrolled, you are required to complete 72 CPE credits before December 31, 2015 (Note: You must complete a minimum of 16 hours of CE credits, of which 2 credits must be on ethics, during each enrollment year of an enrollment cycle.)
6. I was unable to complete the minimum continuing education credits required during an enrollment cycle, due to extenuating circumstances.
Refer to Section 10.6(j) of Treasury Department Circular 230 to determine if you meet the qualifications to request a waiver of continuing education requirements.
7. What are the recordkeeping requirements for ERPAs?
ERPAs must retain the following records for four years:
- The name of the CE Provider organization
- The location of the program
- The title of the program, approval number received for the program, and copy of the program content
- Written outlines, course syllabi, textbook, and/or electronic materials provided or required for the program
- The date(s) attended
- The credit hours claimed
- The name(s) of the instructor(s), discussion leader(s), or speaker(s), if appropriate
- The certificate of completion and/or signed statement of the hours of attendance obtained from the continuing education provider.