pbgc premium filings

[Gary]

say a plan uses a 12/31 val date.

so for 2011 the val date is 12/31/2011.

the 2011 pbgc premium filing is due 4/30/2012

it is often difficult (if not imposible) to obtain data in advance of the deadline to do the val.

anyone experience this? any suggestions? thanks

[SoCalActuary]

Happens to us all the time.

First, the 2011 PBGC premium is based on the benefit on 1-1-2011. So you can perform the 12-31-2011 valuation for the known 1-1-11 benefit, subject to any distributions made during the 2011 year.

But you can't file anyway if you don't have the assets.

For plans of 25 or less, you can use the small plan cap.

At first, the PBGC said they would not enforce penalties for filing after 4-30-12 if the facts are reasonable. But that was a lie. They will change interest and penalty if the client filing is late.

You must use that PBGC position to explain why you need valid trust accounting in time to complete the task, and that you are not responsible for late premiums.