PBGC Issues Draft 2015 Premium Filing Instructions Requiring De-risking Disclosures
The PBGC recently submitted draft forms and instructions for 2015 premium filings to the Office of Management and Budget. The draft forms and instructions would require defined benefit plan sponsors to notify the PBGC if they start the process of “de-risking” their plan through annuity purchases or offering lump sum windows (i.e., temporary opportunities to elect a lump sum in lieu of future annuity payments where a lump sum would not otherwise be available). In the revised forms, plan sponsors engaging in these de-risking activities would be required to report the number of participants involved. Pension de-risking activities have become increasingly more common in recent years and can result in substantially reduced premium payments to the PBGC. The PBGC cited a lack of visibility and the fact that premiums and investment income on premiums are a major source of income for the PBGC in support of the revised forms. At this time the PBGC reports no intention of making the de-risking data that it collects publicly available.