Question of Post-Distribution Certification

[Pension RC]

I am preparing PBGC Form 501 for a DB plan that terminated and has paid everyone out, with the exception of about a dozen missing participants, who will be reported on the Schedule MP. A Form 5310 was filed, but the determination letter hasn't been received yet. My reading of the PBGC Form 501 instructions is that for line 3b (Date of receipt of IRS determination letter), if the plan isn't relying on the distribution deadline based upon receipt of the determination letter, line 3b can be left blank. Is this correct?

Thanks for any responses!

[My 2 cents]

This is what the instructions say for line 3b:

"If your distribution deadline is the IRS determination letter distribution deadline described in section II.H.1, enter the date of receipt of the IRS determination letter with respect to the plan’s tax-qualification status upon termination."

I am not sure what they like to see for items that are not applicable, but in your case this item does not appear relevant since you are not using the IRS letter as a reason for not meeting the normal PBGC deadline. If it will take N/A, you might want to put that in (or PENDING or leave it blank). You might even call the PBGC to see what they suggest.