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PBGC Proposes Changes to Plan Reporting Requirements


September 2015

Section 4010 of ERISA requires reporting to the Pension Benefit Guaranty Corporation (PBGC) of actuarial and financial information by plan sponsors of certain underfunded single-employer defined benefit pension plans. The PBGC develops regulations implementing the 4010 reporting requirements and has announced proposed changes to its regulations to reflect the provisions of the Moving Ahead for Progress in the 21st Century Act and the Highway Transportation and Funding Act of 2014.

The PBGC also proposes to modify Section 4010.11(a) of the current regulations, which allows reporting waivers if the aggregate underfunding of pension plans in a controlled group does not exceed $15 million. The proposed rule would revise this waiver to limit it to controlled groups with fewer than 500 participants. The proposed rule also adds a waiver to the extent reporting is required solely on the basis of either a statutory lien resulting from missed contributions over $1 million or outstanding minimum funding waivers exceeding the same amount, provided that the missed contributions resulting in the lien or minimum funding waivers were reported to the PBGC under the Reportable Events regulation by the deadline for the 4010 filing.

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