Enrolled Retirement Plan Agent Program (ERPA) - Do ERPAs need a PTIN?
The answer is maybe.
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 are not 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.
So, if you never anticipate preparing any tax return for compensation, you probably do not need a PTIN. For example, if you work exclusively in the determination arena and only prepare Forms 5300, 5307 and 5310, chances are, you will not need a PTIN. Likewise, if you only perform plan administration and prepare Forms 5500 you are not 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 successful completion of a CE program, your CE provider can report your CE credits electronically. You can then access your listing of credits using your PTIN. This will aid in keeping track of your annual CE requirements as well as your 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).
