PBGC Proposes Changes to 5500 Schedules R and SB

By John Iekel • August 17, 2018 • 0 Comments
The Pension Benefit and Guaranty Corporation (PBGC) has proposed changes to two schedules to the Form 5500 — Schedule R, Retirement Plan Information, and Schedule SB, Single-Employer Defined Benefit Plan Actuarial Information.

Schedule R

The PBGC is proposing to modify Schedule R to obtain information from single-employer\ plans related to unpaid minimum required contributions. Single-employer plans are required to report the amount of unpaid minimum required contributions on Schedule SB and, in most cases, report additional information about the unpaid (missed) contributions to PBGC on the applicable PBGC form (i.e., Form 10 or Form 200). In some cases, this PBGC reporting requirement is waived (e.g., if the contribution is made within 30 days of the due date).

The PBGC says that it has found that a significant number of plans that are required to file these PBGC form(s) do not. As part of its enforcement effort, PBGC regularly contacts plans that report unpaid contributions on Schedule SB if the applicable PBGC form is not received. With limited exception, the PBGC cannot distinguish between plans that were required to report missed contributions and those that qualified for a regulatory waiver; consequently, the PBGC ends up contacting many plans for which reporting was waived.

The PBGC has proposed modifying Schedule R by requiring PBGC-insured single-employer plans that report unpaid minimum required contributions on Schedule SB to check a box indicating whether PBGC reporting of the missed contributions was waived or required (and if required, whether such reporting requirement has been satisfied). The PBGC is proposing this addition of information to enable it to limit its contact to plans that were required, but failed to, report information about unpaid contributions to the PBGC.

Schedule SB

The PBGC is proposing to modify line 23 to eliminate three boxes representing mortality tables that are no longer applicable.

Public Comments Welcome

PBGC is soliciting public comments to:

  • evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility;

  • evaluate the accuracy of the agency’s estimate of the burden of the proposed collection of information, including the validity of the methodologies and assumptions used;

  • enhance the quality, utility, and clarity of the information to be collected; and

  • minimize the burden of the collection of information on those who are to respond.

The PBGC will accept comments through Oct. 20, 2018. The proposed changes will become effective unless comments result in modifications.