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PBGC standard termination


Jakyasar
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Hi

DOT is 12/31/2020

NOIT - termination notice - given by 10/31/2020 - to satisfy 60 days

NOPB - notice of benefits - given by 11/9/2020

Can I file 500 with PBGC on 11/10/2020 or have to wait till after 2021?

I believe it can be done earlier i.e. do not have to wait till 1/1/2021 but cannot remember.

Thank you

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I'm not sure, instructions just say before 180 days following PPTD, but do not say must be after the PPTD.

Not that is holds any official weight, the graphical timeline bar in the instructions do start at PPTD and end 180 days later for various compliance items including the NOPB and the 500.

But if there is no problem issuing NOPB before 12/31, why would there be one with the 500 filing. If you file, what's the worst that happens? PBGC rejects and makes you refile after 12/31.

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Thank you for your input. I have done this many years ago and PBGC had no issue. The problem here is that if they reject and do not let me know in a timely fashion, can blow the time line.

I will wait till early 2021 to do it. 

Have a great weekend.

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Unless the PBGC changed their rules in the past few years, filing the Form 500 prior to the actual termination date is not a problem as long as everyone has received the NOIT and NOPB.

One thing you do want to be careful of is you are filing for an IRS DL on termination, make sure you file the IRS DL before the Form 500 to get the extended distribution window. If you're not worried about the extended window you can file the Form 500 at any time after you confirm participants received the required notices.

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Just to confirm, we recently did a PBGC termination where the entire process was finished a day or two after the effective date of the termination.  A word of caution, however:  it's a really good idea to have a DETAILED schedule of what everyone needs to do when.  It's easy to get off track and have the deadlines get away from you.  This was especially true in our case (and probably most situations), because the process involved:  the client (plan sponsor), the attorney (us), the TPA/actuary, and the investment advisor (who was working on the procurement of the annuities).  It was clear to us from the beginning that everyone was underestimating their part of the project and the detailed to do list advised everyone of the details of their responsibilities and kept us all on track.

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