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PBGC requesting extra information with form 501


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On terminations where we have filed a form 501 with the PBGC within the last 3 months they are asking for:

1) A copy of the current plan document; and

2) Proof (cancelled checks) of each distribution

Does anyone know why this is happening or why there is no announcement?

Thank you.

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Why? could be lots of reasons.

My hunch: it's a way to avoid most audits, by requiring the submission of information that would be requested in any audit.

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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For what it's worth, this was just copied from the Form 501 instructions on the PBGC website:

The following documents must be attached to the Form 501:
  • For individuals for whom annuities were purchased (this includes non-missing and missing participants): a copy of the annuity contract(s), certificates, and/or written notices to the participants, identifying contact information for the annuity provider, group contract numbers for that annuity provider and a list of participants entitled to annuities from that annuity provider
  • For individuals who received a lump sum distribution, a copy of the cancelled check or bank statement with the individual’s name and distribution amount.
  • For each missing participant whose designated benefit was transferred to PBGC, a separate Attachment B must be attached to the Schedule MP

Does it matter why the PBGC wants all of this information? The Form 501 instructions make it clear enough that they do. As noted above, perhaps it is to facilitate any audit the PBGC may conduct.

Always check with your actuary first!

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