Reportable Events and Participant Notices

[AndyH]

Is there currently a requirement to notify PBGC if a quarterly is missed for a plan with 101-499 participants on every day of the prior year and in the case where missed payments are less than $1 million cumulatively? What about a funding deficiency under $1 million for a plan of the same size?

As far as I can tell, a plan under 100 participants is exempt and a plan 101-499 is exempt because a PBGC Notice under ERISA 4011 was not required for both the prior and current plan years because ERISA 4011 was repealed effective for plan years beginning after 12/31/2006.

But I keep reading outlines and publications describing reportable events for missed quarterlies as if the rules are unchanged.

How do others interpret this situation?