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Guest Article

(From the March 17, 2008 issue of Deloitte's Washington Bulletin, a periodic update of legal and regulatory developments relating to Employee Benefits.)

PBGC Issues Proposed Regulations to Implement PPA Changes Regarding Actuarial Reporting Under ERISA § 4010

To implement changes made by PPA, PBGC issued proposed regulations for determining the persons required to report under § 4010, providing a reporting waiver for controlled groups with $15 million or less in underfunding, modifying the standards for determining plans exempt from the actuarial information requirements, and revising the actuarial information requirements. 73 FR 9243 (February 20, 2008). The proposed regulations are available on the PBGC's Web site, at www.pbgc.gov/docs/E8-3124.pdf.

Overview of PPA Changes

ERISA § 4010 requires sponsors of single-employer pension plans to report various financial information to the PBGC. Prior to PPA, ERISA § 4010 generally required reporting only if the:

Aggregate unfunded vested benefits of all plans maintained by members of the controlled group exceeded $50 million, disregarding plans with no unfunded vested benefits (the "$50 Million Gateway Test"),
Conditions for imposing a lien under ERISA § 302(f) for missed contributions exceeding $1 million had been met by any member of the controlled group, or
Minimum funding waivers had been granted by the IRS in excess of $1 million to any plan maintained by any member of the controlled group and any portion of the waiver was still outstanding.

PPA Amended ERSIA § 4010:

To replace the $50 Million Gateway Test with a test based on the funding target attainment percentage of each plan in the controlled group. Reporting is required if any plan maintained by any member of the controlled group has a funding target attainment percentage of less than 80 percent.
By amending the minimum funding waiver provisions of the Internal Revenue Code which are referenced in ERISA § 4010.
To require additional items be included in the information submitted to PBGC.

PBGC Reminds Non-Filers to Submit Information on PBGC Website

PBGC reminds filers for the immediately preceding information year, who are not required to file for the current information year, that they must submit information in accordance with directives on the PBGC website to demonstrate why a filing is not required for this year. This would apply, for example, where a filer was required to file for the information year ending on December 31, 2007 based on the $50 Million Gateway Test, but is not required to file for the information year ending on December 31, 2008 under the new funding target attainment percentage test.

The information in this Washington Bulletin is general in nature only and not intended to provide advice or guidance for specific situations.

If you have any questions or need additional information about articles appearing in this or previous versions of Washington Bulletin, please contact: Robert Davis 202.879.3094, Elizabeth Drigotas 202.879.4985, Mary Jones 202.378.5067, Stephen LaGarde 202.879-5608, Erinn Madden 202.572.7677, Bart Massey 202.220.2104, Mark Neilio 202.378.5046, Martha Priddy Patterson 202.879.5634, Tom Pevarnik 202.879.5314, Sandra Rolitsky 202.220.2025, Tom Veal 312.946.2595, Deborah Walker 202.879.4955.

BenefitsLink is an independent national employee benefits information provider, not formally affiliated with the firms and companies who kindly provide much of the content and advertisements published on this Web site, including the article shown above.