PBGC Missing Participants Program

[ConnieStorer]

I terminated a Cash Balance Plan in 2018.  We were unable to locate two participants so their account balances were sent to the PBGC under the missing participants program.  The PBGC audited this termination and sent me and email stating that the payments made for the two missing participants was not calculated correctly.  Both individuals had benefit values in excess of $5,000.  I was told I needed to use their standard calculation method applicable to traditional defined benefit plans.

Is this correct?

If the lump sum value was less than $5,000 would the account balance be the correct amount to send to the PBGC.

Thanks,

[ConnieStorer]

After reading some posts on the message board I realize why the PBGC method of calculating the payment is based on the monthly annuity rather than the hypothetical account balance.  Any insurance company would do the same based on a deferred annuity with lump sum options.