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PBGC 2015 Premium Filing Instructions Approved

The Pension Benefit Guaranty Corporation (PBGC) announced on March 9 that the Office of Management and Budget has approved the 2015 PBGC premium filing instructions. It also said that its electronic system for making filings, My PAA, will now accept electronic premium filings for plan years beginning in 2015.

The PBGC said that it made few changes to the filing requirements, and they are largely the same as those for 2014 filing. Following are key changes that the PBGC did make for 2015 filing.

Changes in Premium Rates

The following changes were made to premium rates:

  • The per-participant flat-rate premium rate for single-employer plans is $57, up from $49. For multiemployer plans that rate is $26, up from $12.
  • The rate per $1,000 of unfunded vested benefits is $24, up from $14.
  • The MAP-21 cap on the variable-rate premium cap is $418 times the number of participants, up from $412 times the number of participants.

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New Due Date for Small Plans

The due date transition rule for Small Plans is now fully phased in. That means small plans are now subject to the same due dates as other plans. In general, the 2015 due date for a calendar year plan is Oct. 15, 2015.

New (Optional) Contact Information

Plans which prefer that the phone number shown on PBGC’s Is my Pension Insured webpage be a number other than that of the plan administrator may now provide an alternative phone number for that purpose.

Risk Transfer Activities

Information about the number of former employees involved in certain recent risk transfer activities (i.e., annuity purchases and lump sum windows) now must be reported. Because the reporting requirement for 2015 applies to a much longer period than for subsequent years, reasonable estimates may be reported instead of exact counts.

Certification Procedures for Uploaded Filings

In prior years, the person responsible for uploading was permitted to do so before the plan administrator had manually signed a hard copy of the premium data generated by the private sector software. Starting with 2015 filings, to ensure the filing has been certified by the plan administrator, the uploader must wait until the manual certification has been done. If the enrolled actuary is also certifying manually, the same rule applies with respect to the actuarial certification.

After the filing is uploaded, the My PAA-generated confirmation number must be written on the certified paper copy (to be retained in plan records).

The detailed information about certifying uploaded premium filings in the My PAA Users Manual has been modified accordingly.

Additional Guidance on the Small Plan Lookback Rule

PBGC approval is required to start using the look back rule in 2015 after opting out in 2014, and, with limited exceptions, to opt out of the look back rule starting with 2015. The instructions have been expanded to clarify the exceptions and provide information on how to request approval.