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Missed the deadline to file the PBGC 500


JARichardson

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NOIT went out in December 2017 for a 1/31/18 plan term date.  Plan anniversary was March 1.  Plan has been frozen since 2006.  When the new rates went  into effect March 1 the plan was more underfunded than the client anticipated.  They took a couple months to figure out if they were going to go ahead with the plan term.  Now they want to move forward and we're past the 180 days to file the PBGC 500.  They really want to get it paid out by year end but especially by PYE.  Its not clear to me what the options are.  I see where you can change the proposed term date - but not more than 90 days.  So have we missed that window too?  Has anyone been in this situation?  Is there anything we can do at this point other than start over?

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You have a 60-90 advance NOIT window, so assuming NOIT issued 12/2, you can push PPTD back to 3/3 (double check your day count to be sure), which gives you a few days to pound out the 500 AND the notice of plan benefits to participants (NoPB) - but need to communicate the change in PPTD to participants as well. This may or may not be possible. If you can pull if off, great, but if not, I think you have to start the process over beginning with a new NOIT and PPTD timeline. The PBGC is very stringent on their plan termination rules and timelines.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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