Prior PBGC filings

[Jakyasar]

Hi

May be taking over a DB plan where prior TPA is most uncooperative.

Client does not have any prior PBGC filings and got a premium payment that seems to be high, according to him.

He does not remember what happened in the past 2 years.

Like EFAST for 5500SF, is there a way to find a list of prior PBGC filings?

Thanks

[truphao]

If you get the access to the PBGC MYPAA portal you should be able to see the history of prior filings right there.  Which might be a challenge if the prior TPA is the "most non-cooperative".  I just had the similar experience - the prior TPA made sure everything is the most difficult for the takeover.

[Jakyasar]

Prior TPA will not provide any access. I tried to get in with my access hoping to get something but to no avail.

[truphao]

Again, just had a similar experience.  I ended up drafting aa detailed email outlining the professional responsibility of the prior actuary to transition the work.  That did it.  Not the best nor the enjoyable experience but it might do the job.

[Lou S.]

If the client is setup as the Administrator on the PBGC site, they can grant you access by inviting you. If the prior TPA did everything you might need their assistance.

As for the premium, if it's a small plan using the lookback, the premium might be high since the interest rates lag what's been going on.

 

[truphao]

Lou, I am going to start a new topic on this notion.....

[Jakyasar]

Trying to avoid any unpleasant experiences with prior TPA.

Lou, I am aware of the reasons but I was asked why and that is why trying to get some info for 2023, I have nothing to work with at this time.

So I told the sponsor to pay and if needed to be corrected, will do later.

Also, thank you for the suggestion but I think the sponsor is clueless prior TPA never explained anything to them.

If I accept this plan, I have a feeling I am going get a lot crap info, if any.

To be seen.

[Lauren]

You can ask the PBGC to assign you as the Filing Coordinator. I did this a couple of weeks ago, and it was painless. My situation was a little different, though. I was already the actuary but not the Filing Coordinator. The Filing Coordinator left the TPA firm, so there was no one to manage the roles. I sent the PBGC a quick email via My PAA explaining the situation, and they updated it within a few days.

[Jakyasar]

Thank you, nice advice but I am not yet hired nor have decided to take over the client. I doubt PBGC will allow me to be filing coordinator yet, especially without the client's consent/approval nor I want to be.

[Lauren]

I missed that this is a possible takeover (read thread too quickly!). I agree that they probably won't let you be Filing Coordinator yet. 

[david rigby]

Hold on here.  Is there an actuary at this "most uncooperative TPA"?  If so, it may be worth noting this from the Actuarial Code of Conduct:

• PRECEPT 10. An Actuary shall perform Actuarial Services with courtesy and professional respect and shall cooperate with others in the Principal’s interest.

I agree that you are not entitled to be the Filing Coordinator yet, but someone should provide you copies of previous forms that you may request.  IMHO, this should not be ambiguous.

[Hojo]

3 hours ago, david rigby said:

Hold on here.  Is there an actuary at this "most uncooperative TPA"?  If so, it may be worth noting this from the Actuarial Code of Conduct:

• PRECEPT 10. An Actuary shall perform Actuarial Services with courtesy and professional respect and shall cooperate with others in the Principal’s interest.

I agree that you are not entitled to be the Filing Coordinator yet, but someone should provide you copies of previous forms that you may request.  IMHO, this should not be ambiguous.

If you are not yet the TPA then I don't think that Precept 10 would apply in this case.  I'm not going to just provide information to another actuary because they ask for it unless either 1) they have a signed service with the other actuary, or 2) the client asks me to share the information directly (in which case I would simply send it to the client and they can share as they see fit).

[Jakyasar]

Wow, thank you for additional comments.

I am trying to avoid any ugly threats, will see if I am hired first.