Government Affairs
The Pension Benefit Guaranty Corporation (PBGC) has posted Q&A concerning how the Coronavirus Aid, Relief, and Economic Security (CARES) Act affects missed contribution reporting requirements and premium filings for single-employer plans.
Regarding missed contributions, the Q&A address:
- How the delay of the due date for required contributions that would have been due in 2020 affects the requirement to report a failure to make a minimum required contribution provided in section 4043.25 of the PBGC’s Reportable Events regulation.
- When reporting is due and which form should be used when a required contribution that would otherwise have been due during 2020 is not made by Jan. 1, 2021.
Regarding premiums, the Q&A address whether:
- the extended due date for required contributions has any effect on the treatment of contributions receivable for VRP purposes; and
- the plan administrator may amend the filing to increase the originally reported asset value by the discounted value of the prior year contribution made after the premium filing date and then request a refund in the event that a contribution for the prior year is made after the premium is filed.
Regarding the PBGC Single-Employer Program, the Q&A address whether the PBGC will:
- continue to review distress termination applications, and whether a notice can be filed with financial projections that may be subject to change in the next few weeks/months;
- initiate termination of pension plans during the pandemic;
- suspend efforts to collect termination liabilities until 2021; and
- suspend Early Warning Program inquiries during the pandemic.
The Q&A also provide general information about the pandemic’s impact on the PBGC’s Single-Employer Insurance Program operations.
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