PBGC sending out non filing notices for plans that have the IDA extension

[SSRRS]

Hi,

I hope all is well with everyone. The PBGC has been sending non filing notices for plans that were due 10/15/2021, even though these plans are entitled to the  January 2022 IDA extension. Clients are getting upset. Any thoughts, insights, or advice would be much appreciated. Thank you !

[C. B. Zeller]

Although it is not required, you could notify the PBGC that the sponsor is eligible for disaster relief before actually submitting the comprehensive premium filing; that could help avoid having them send a notice to the sponsor. See emphasized section below.

https://www.pbgc.gov/prac/other-guidance/Disaster-Relief#notifying

Quote

Notifying PBGC of Your Eligibility for Disaster Relief;

Premium filings: Notify us by providing certain information as part of the Comprehensive Premium Filing. See the Filing Instructions for the applicable plan year for details. We also encourage filers to notify us by email to premiums@pbgc.gov as soon as reasonably possible that you are eligible for disaster relief. The email should contain the following identifying information:

the number of the applicable IRS News Release

plan information, i.e., plan name, EIN, plan number, and

the name and address of the person affected by the disaster.

The name and address of the affected person may be omitted if the plan administrator’s address reported in the most recently submitted premium filing is in the applicable disaster area.

In situations where a filer is unable to submit, or anticipates difficulty in submitting, the Comprehensive Premium Filing by the end of the relief period, the filer should notify us by sending an email to premiums@pbgc.gov with the same information listed.

 

[SSRRS]

Thank you, C.B. Zeller.

[thepensionmaven]

Some of our clients have received late payment invoices, as well.

 

[SSRRS]

21 hours ago, thepensionmaven said:

Some of our clients have received late payment invoices, as well.

 

[SSRRS]

21 hours ago, thepensionmaven said:

Some of our clients have received late payment invoices, as well.

 

Thank you. The clients that received late payment invoices, was their a mention of disaster relief on their forms that were filed?

[Mike Preston]

4 hours ago, SSRRS said:

Thank you. The clients that received late payment invoices, was their a mention of disaster relief on their forms that were filed?

The whole point is that they aren't due yet.

[SSRRS]

On 11/12/2021 at 5:12 PM, Mike Preston said:

The whole point is that they aren't due yet.

Thank you Mike. As always, you are right to the point. Is there any reason that the PBGC is making things unpleasant? Clients get very upset when they receive these notices and it's a waste of time etc.

[thepensionmaven]

I think the reason is that these notices are spit out by computer that has not been programmed to separate notices by state?