Received email from the pbgc

Hi,

A PBGC covered plan received the following email from the pbgc...

This letter is to inform you that the Pension Benefit Guaranty Corporation (“PBGC”) was notified that a Reportable Event has happened.  According to the information we have received, "A" Corporation (the “Plan Sponsor”) has failed to make the required minimum contributions

1. Who are they referring to when they say they were notified? Who could have notified them?

2. The minimum required contributions that they are refering to are the possible  MRC that would be shown on the 5500 (that were not filed for a few  years) or are they referring to the pbgc annual.premiums that have not been paid?    Thank you as always for any insights. 

Is "A" actually your client?  Do they have a missed MRC?

Looks like a scam to me.  Did it come from a specific person?  Any correspondence I have received from PBGC has been well written and comes from a specific person w/ numerous others cc'd. 

I'm looking at the last "hey you owe a Form 10" correspondence the PBGC sent a client a year ago, and the text you provide here is similar but not identical.  In fact, the PBGC did not use the passive voice that the reportable event "has happened."  They directly said the PBGC found the unpaid MRC on the 5500 and immediately provided the website for more information on the filing requirements at www.pbgc.gov.

Thank you Effen and Bri. As always your knowledge is much appreciated. There were no missed MRCs shown on the 5500s that were filed. So wondering who told them that this is this case. Meaning, even if this is indeed the case, who informed them of this. However, they don't have a missed MRC. Unless not filing a couple of 5500s is considered a missed MRC?

Speculating but if you filed PBGC premiums and not a 5500 that might trigger a response from the PBGC but I don't know for sure.

You could discuss with your client reaching out the PBGC directly with a copy of the e-mail asking the PBGC to verify the authenticity.

If it is from the PBGC, and there are no missed MRCs you could let the PBGC know their information is incorrect.  If there actually are missed MRCs, you could file the required Form 10(s). 

But if there are also still missing 5500s, the plan may have some additional issues to fix.

Just observing that you edited your OP, but the thread doesn't say "edited", which I find odd?  The way you have it worded now, does not look as much like a scam as it did previously.  Hmm, I edited my first post to remove the name as you did, but it doesn't say "edited" either.  I guess they changed that functionality.  

Anyway, I think not filing a 5500 could cause the PBGC to assume they missed an MRC. Also, if their funded ratio was low, the PBGC considers quarterly contributions to be "required minimums".  Years ago they put a lien on one of my clients for missing quarterlies.    

Good advice above.  My suggestion is to carefully inspect all the relevant filings and dates.  For example, your checklist should include:

• making sure there is no typo (especially the EIN) on the 5500 and/or PBGC filing(s).
• verifying (don't assume) the exact date each payment was made.  For example, if the 09/15 payment was made on 09/16, that is late.