PBGC Annual Funding Notice

[JAY21]

I slugging my way through my first Annual Funding Notice for a PBGC plan under 100 lives. It replaces the SAR report.

I'm using the PBGC model notice and following the instructions at the bottom of the model notice which refers me to sections under ERISA 303 for definitions of each component (e.g., plan liabilities). Reading those ERISA sections they do not refer or allow any use of prior year data for this FTAP purpose which is no surprise as even the IRS relief was not in the Code itself.

Question: Is there any ERISA/DOL relief similar to IRS relief to to use prior year data for small EOY plan valuations ? If not, I end up with a different PBGC FTAP for the same year than my funding/distribution FTAP under the IRS rules/relief.

2 different FTAPS results for the same year ???