Individuals do not need a preparer tax identification number (PTIN) when they apply to be an enrolled retirement plan agent (ERPA) or when they seek to renew the designation, the IRS has announced (Notice 2011-91, 2011-47 IRB).
An ERPA is an individual who has been approved by the IRS to practice before the agency on certain retirement plan issues. An ERPA may represent taxpayers before the IRS on matters involving the Employee Plans (EP) Determination Letter program; the EP Compliance Resolution System, the EP Master and Prototype Program and Volume Submitter Program; and Form 5300 and Form 5500 filings (but not with respect to actuarial forms or schedules).
Currently, Circular 230 requires ERPA candidates to have a valid PTIN. Circular 230 also requires individuals to have a PTIN to renew their ERPA designation.
As the result of a change in policy, effective immediately, the IRS is discontinuing the requirement that ERPA candidates and individuals renewing their ERPA status have a valid PTIN. However, an ERPA must have a PTIN if he or she prepares or assist in the preparation of any return not exempt from the PTIN requirement under Notice 2011-6, 2011-3 IRB 315, or future guidance. The IRS reported that it will revise Circular 230 to reflect the change.
Reference: PTE §39,010.20