EOY Val & PBGC premium filing under new rules.

[flosfur]

Is there some relief/technical correction in the pipeline so that PBGC filing can be completed based on prior year valuation as was the case before 2008?

If not, what are people doing?

[zimbo]

Basically the choice is to wait until after the 12/31/08 plan asset values are in or, if you are quite sure that the plan would have a significant variable rate premium, consider using the $5 per participant squared approach and file using that amount as the variable rate premium. In that case, the forms can be filed as early as now. But, you'd better be sure about the variable rate premium otherwise you may be costing your client money in higher premiums.

[Effen]

prior post

I don't think the 2008 PBGC premium includes the 2008 Accrual, so you should be able to determine the 2008 premium even though you haven't done the 2008 valuation. You will most likely need to run your (12/31/07 - ie 1/1/2008) numbers using PPA assumptions.

Last thing I heard about technical corrections was - don't look for anything until after the elections, and even then maybe not until 2009. (Why do we pay these people?)

[JAY21]

What do we have to use for assets for PBGC premium ? if it's the actuarial valuation of assets as of the val ate for 2008 then an EOY val might be using the 12/31/08 assets and thus we wouldn't be able to do PBGC premiums until after 12/31/08 even though I agree the 2008 accrual isn't included.

[Effen]

That is correct, but they aren't due until 4/30/09, which should be possible, but not necessary easy to do.

[AndyH]

So is the consensus that end of year 2008 val liabilities and assets are used for 2008 PBGC premiums and due by 4/30/2009? Or is the 2008 accrual somehow backed out?

Does seem that the participant count is still as of 12/31/2007.

Oh, and does a 12/31/2008 standard termination date qualify for the variable rate exemption if that is the liability calculation date?

[JAY21]

When I read the PBGC premium instructions it seemed fairly clear that it's the Funding Target (Premium Target in PBGC lingo) valued at 12/31/08, which does not include the 2008 accrual, and then the 2008 EOY assets which do not include any contributions for the year.