PBGC e filing

[Gary]

Can an actuary or representative at the firm preparing the client's PBGC returns sign as the plan administrator?

The e filing allows for anyone to have the "permission" to serve and sign as plan administrator, so it seems to indicate that someone other than the actual plan administrator can sign the return as serving plan administrator.

Any thoughts on th is?

Thanks.

[WDIK]

I would think that to sign as plan administrator you would need to either

a) be legally designated as the plan administrator, or

b) be legally authorized by the plan administrator.

[Andy the Actuary]

What you may be able to do is obtain a waiver (similar to a power of attorney) from the client that would authroize you to push the Plan Administrator button. However, you would only do this if the Client is registered under his/her own name and you have been given the user id/password information.

[Guest merlin]

If you upload the filing to the PBGC rather than importing it there is no electronic signature required. See p. 36 of the MyPAA manual. All that is required is that the PA (and the EA if necessary) sign a hard copy for the file within 2 weeks of the upload (p.39).

This is the method we're using for our clients. Also, we've opted for payment by check with a voucher. This plus printing out the hard copy to be signed and returned make for a little more paperwork than before, but it most closely resembles the old filing system from the client's perspective. We also didn't want to get involved with checking account or credit card information. Plus, it avoids the issue of the client who can't or won't set set up a MyPAA account.

[AndyH]

Well, I have a client with no computer or email so I called the PBGC yesterday about this and was told that the solution is to obtain the PA's permission to perform all of the functions, including signature, and them mail them a paper copy "if you want".

Merlin, I heard that what you suggest was in the instructions somewhere and that it might avoid the signature but a colleague told me today that he did try what you suggested and was required to sign electronically.

Confused.

[Guest saeissler]

I do the upload method also. I am authorized as the filing coordinator and preparer and enrolled actuary. I can submit the filing. The client signs and retains the form I send them. The client mails the PBGC the voucher and check.

[AndyH]

Thanks; I'll assume my colleague did something wrong.

It would be nice if the PBGC practioner hotline person knew this.

[Guest merlin]

The PBGC rep I spoke to on the help line agreed with my understanding.

[AndyH]

That's it. I'll call the problem resolution line and complain. I'll probably get the same person that gave me the bad info, just to save me time. They're very helpful there.

[mwyatt]

Had been putting this chore off and glad that I ran into this thread before getting too involved. Cranked them all out this afternoon and will mail tomorrow the forms for signing and vouchers. Yes, upload is most definitely the way to go (unless you want to turn what was once a 10 minute chore into an unending travail having your clients set up accounts etc.). Just upload, then send the client the printed form to sign along with the voucher and you're all set w/o wasting a bunch of time (do our clients really want to get involved in all this folderal? and as Andy pointed out, there are still some Luddites out there - not so uncommon when you figure out that small DB plans tend to have older sponsors).

[mwyatt]

One nitpick however: you would think that the PBGC's coders could have figured out how to put the EIN, PN, plan year, premium amount, and plan name on the Payment voucher. They at least got the confirm ID on there.

[AndyH]

Doesn't this upload and voucher system require that the actuary/TPA enlist as filing coordinator? And doesn't that require an escalation in potential responsibility/liability? That is the concern I've heard in some circles. Does anyone share such concern?

[tymesup]

Doesn't this upload and voucher system require that the actuary/TPA enlist as filing coordinator? And doesn't that require an escalation in potential responsibility/liability? That is the concern I've heard in some circles. Does anyone share such concern?

Once it's uploaded, it can't be changed. Therefore, we're planning to send the form to the client to look at before authorizing us to upload. It adds work, but seems to lessen our exposure.

[mwyatt]

Yep, you do need the TPA/Actuary to act as filing coordinator. However, in the small plan market trying to get your clients to go through the steps to establish an account is akin to herding cats. I'll take the "liability" (only signing up for signing as actuary and the ability to look at historic records - certainly don't sign up for signing powers) to save boatloads of time.

[Effen]

I guess I'm just the strange one, but I really find the MyPaa system pretty easy to work with once you use it a little. Even my most difficult clients have been able to handle it. I guess I just don't see what all the teeth gnashing is about. I have big plans and small plans and they have all seemed to be able to get it done.

[mwyatt]

The "teeth gnashing" is due to the fact that before, you completed the form, printed it out, and mailed it to the client for payment. Total time, about 15 minutes and you're done.

The "upload" scheme comes about the closest to this type of timing. Importing, then chasing your client down to get them to sign up, talking through the form, etc., adds a fair amount of time to this approach (and around this time of year, when you're busy chasing the usual suspects down, extra time is a luxury).

[Effen]

Your right, "before, you completed the form, printed it out, and mailed it to the client for payment.", now you just complete the form and hit a button. No letter to write, no forms to mail, nothing to upload. Just hit the button and the client has the form.

I agree the first year involves a little hand holding, but once that is behind you we've found things run fairly smoothly. We are on yr-2 with the system and have only had a few hand-holding calls. Most went very smoothly. We just spend our 15 minutes typing it in, and we're done.

Not all change is bad, if you give it a chance. Ultimately what ever works best for you is the right answer. I was just pointing out that I don't find MyPAA all that difficult or problematic.

[Gary]

Regarding file uploads.

What software are people using?

My BNA software is not compatible for the PBGC filing as it says 'the PBGC now requires electronic filing" and provides no form or further information.

Thanks.

[abanky]

we are using relius government forms... it works pretty good for the most part

[SoCalActuary]

We went with Datair's Pension Reporter, and it worked very well. They also helped with the training, holding a free web-cast. Their product got to the users sooner than some other products, so we were less stressed at meeting our deadlines.

[AndyH]

wish I could use past tense.

[tymesup]

wish I could use past tense.

Sure you can. This time of year, our mental state is way past tense.

[Effen]

I thought that was when you dreamed a lot about a couple of tee pees ..... oh wait, that is when you are too tense