PBGC Form 10 Waiver

[AndyH]

Does anybody know what the third bold requirement means within the context of whether an active participant reduction might require the filing of Form 10 for a plan that is 80% funded? I have asked this here and elsewhere before and have never found an answer.

Funding-based waivers: For the event year:

- No variable rate premium (see Part IV.B);

- Less than $1 million in unfunded vested benefits (see Part IV.C); or

- No facility closing event/80% funded: The plan is at least 80% funded for vested benefits (see Part IV.D) and the active participant reduction would not be reportable if only those participant reductions resulting from cessation of operations at one or more facilities were taken into account.

[SoCalActuary]

It is a big-plan exemption, where combined turnover and plant closings took the plan into disclosure rules.

With this exemption, they get to ignore the regular turnover.

[AndyH]

So does that mean that

Plan A (with 101 participants) that is 81% funded and had a 21% active participant reduction but had no plant or facility closing must file Form 10, but

Plan B (with 101 participants) that is 81% funded and had a 21% active participant due to a plant closing is exempt?

Does that make any sense?

[SoCalActuary]

Andy... you asked if a plan had fact pattern A or fact pattern A, with no difference.

A- no plant closing but 20+ turnover

B- plant closing with under 20% turnover and under 20% plant closing totalling 20+.

B-type plans get the exemption.

[AndyH]

Sorry, I will edit my question so hopefully it will make more sense.