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PBGC Premium Filing Instructions Include Filing Errors, Expanded Examples

The Pension Benefit Guaranty Corporation (PBGC) has released the Premium Filing Instructions to be used for 2018 plan years. The new instructions, which now include a section alerting practitioners to the most common premium filing mistakes and expanded examples in the section about determining premiums in a year when a plan is involved with a spinoff, merger or consolidation, are available on the PBGC website.

Key Changes

The PBGC says that the filing requirements for 2018 are almost the same as those for 2017, but there are some changes for 2018 filing. Following are the most important changes.

Changes in single-employer premium rates. The flat-rate premium is $74 per-participant, up from $69; the variable-rate premium is $38 per $1,000 of unfunded vested benefits capped at $523 times the number of participants, up from $34 capped at $517 times the number of participants.

Expanded information. The PBGC has expanded the following:

1. examples in the section about how to determine premiums in a year when a plan is involved with a spinoff, merger or consolidation; and
2. the section about short plan years, to provide additional information for plans expecting to distribute assets during the 2018 plan year pursuant to a standard termination.

Common filing errors. The PBGC added a list of common filing errors and provided details about those errors in a new appendix. It says that common errors include:

  • incorrect identifying information

  • sending payment without properly identifying plan

  • new plans failing to do a first year filing

  • small plan lookback rule inconsistencies

The PBGC adds that there may be changes in the instructions for paying premiums in 2018.

The PBGC also says that My Plan Administration Account (My PAA) will be ready to accept 2017 filings “in the very near future.”