Exiting PBGC Coverage

Is there a standard procedure for exiting PBGC coverage (i.e., a pension plan was covered, but is no longer covered) aside from simply stopping premiums? More specifically, a takeover of a private entity plan sponsor by a governmental entity. 

Part VI, #13 on the premium filing form allows you to indicate a final filing, with a checkbox to indicate why.  I would assume some filing's due for the part of the year for the time it wasn't governmentally sponsored, right?

Have you tried e-mailing Coverage@pbgc.gov? They should be able to help you out. I don't know if you have to file for a coverage determination.

Very helpful, thank you. 

If anyone has been involved in a similar process, does this cause any problems with the DOL if you mark a 5500 as final showing significant assets at year end?

23 hours ago, EBECatty said:

If anyone has been involved in a similar process, does this cause any problems with the DOL if you mark a 5500 as final showing significant assets at year end?

Yes, it gets very messy.  A little background, effective 1991 a state university established a private corporation to manage its physical maintenance and food-service operations since the state mandated vendors didn't service the locale except at a significant surcharge.  In the mid-90's the DoL posited that these arrangements were governmental, I think it was the California state universities that led that charge. 

However, this employer did nothing and continued to operate it's two pensions as subject to full ERISA compliance; except that the actuary then refused to sign the new Sch SB. The PBGC took them at their word and agreed they shouldn't be covered; but the DoL & IRS demanded the complete 5500 filings be continued.  We applied to the EBSA for an ERISA Advisory Opinion Letter about the Plans status change, and they then dropped their demands for additional filings.  Since it doesn't sound like the plan is merging, transferring, or terminating, just a change in sponsor; I would recommend applying for an Advisory letter, and then asking EFAST how to prepare the 5500 filing for the final year.  I wouldn't trifle with a rejected filing, especially with the new penalty amounts. 

Appreciate it, Nate. That's what I was afraid of.