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“BenefitsLink continues to be the most valuable resource we have at the firm.”

-- An attorney subscriber

Guest Article

(From the September 15, 2008 issue of Deloitte's Washington Bulletin, a periodic update of legal and regulatory developments relating to Employee Benefits.)

PBGC E-Filing Webcasts Are Scheduled

As a result of the Pension Protection Act of 2006 and changes in PBGC regulations, all plans are required to make their premium filings electronically unless an exemption is obtained. For plan years beginning in 2008, previous Form 1-EZ, Form 1 and Schedule A are replaced with a new Comprehensive Filing. The earliest Comprehensive Filing due date for 2008 calendar year plans is October 15. PBGC has scheduled two Webcasts -- on September 23 & 25 -- to provide instruction on the e-filing process. Registration is available on the PBGC website (www.pbgc.gov).

Changes for 2008 PBGC Premium Filings

In addition to the new Comprehensive Filing, the following additional changes are noted for 2008:

Flat-rate premium increase. The per-participant flat-rate premium for 2008 is $33 for singleemployer plans and $9 for multiemployer plans (inflation adjusted from $31 and $8, respectively, for 2007).

Change in filing due date structure. The due date is either the same as it was under the 2007 rules or later. The due date depends on the plan's size, which is based on the number of participants for which flat-rate premiums were owed for the prior year (i.e., a small plan is one which had fewer than 100, a mid-size plan had 100 or more but less than 500, and a large plan had 500 or more). As summarized in PBGC, Comprehensive Premium Payment Instructions (2008), the filing due dates for pre-existing calendar-year plans are:

Filing Due Date for Pre-Existing Calendar-Year Plans ¹

Plan Size	Flat-Rate Premium	Reconciliation of Estimated Flat-Rate Premium²	Variable-Rate Premium	Reconciliation of Estimated Variable-Rate Premium ²
Small	April 30th after year-end	N/A	April 30th after year-end	N/A
Mid-Size	October 15th during year	N/A	October 15th during year	April 30th after year-end
Large	February 28th during year	October 15th during year	October 15th during year	April 30th after year-end

Changes in how variable-rate premiums are calculated. Changes have been made in the assumptions used to determine unfunded vested benefits and in the measurement date for calculating unfunded vested benefits; the alternative calculation and modified alternative calculation methods are no longer available; some plans now have the option to pay an estimated variable-rate premium and reconcile at a later date without a penalty for late payment; and certain of the variable-rate premium exemptions (including the full funding limit exemption) and the accrued benefit relief rules are no longer available. Also, clarification has been provided regarding when benefits are considered vested.

Webcast Agenda: Overview of PBGC E-Filing Process

There are two types of PBGC premium filings:

Estimated Flat-Rate Filings which are for large plans that are required to pay the flat-rate premium early in the year.
Comprehensive Filings which are for all other purposes. A comprehensive premium filing is used to report the flat-rate premium and related data for all plans, the variable-rate premium and related data for single-employer plans, and additional data (e.g., identifying information and plan-related or filing-related data) for all plans. It is also used by large plans to reconcile an estimated flat-rate premium paid earlier that year.

Both Estimated Flat-Rate and Comprehensive Filings are now filed electronically via My Plan Administration Account ("My PAA") -- the e-filing application on the PBGC Website. Three e-filing methods are available: using My PAA's data entry and editing screens, importing software-prepared filings into My PAA's editing screens, and uploading software-prepared filings to PBGC. Payment can be made within My PAA by automated clearing house, electronic check or credit card -- or outside My PAA by electronic funds transfer or paper check.

PBGC's scheduled Webcasts will describe the three methods available for e-filing, and will focus on using My PAA's data entry and editing screens to prepare, e-sign, pay, and submit a single-employer Comprehensive Filing to PBGC.

¹ Table assumes none of the dates shown are Saturdays, Sundays, or Federal Holidays, and that there has been no change in the plan year.

² If certain conditions are met, late payment interest charges will apply, but late payment penalties will not.

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, 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.