PBGC Issues 2015 Premium Filing Form Draft

By John Iekel • January 13, 2015 • 0 Comments
The Pension Benefit Guaranty Corporation (PBGC) on Jan. 12 issued a draft of the 2015 premium filing form and instructions. It provides information for plans paying premiums for plan years beginning in 2015, including instructions for all the particular forms of data that must be reported.

The filing requirements for 2015 are almost identical to the filing requirements for 2014. Nonetheless, there are some changes for 2015.

Changes in premium rates. The per-participant flat-rate premium rate for single-employer plans is $57 up from $49. For multiemployer plans that rate is $26, up from $12. The rate per $1,000 of unfunded vested benefits is $24, up from $14. The MAP-21 Cap on the variable-rate premium cap is $418 times the number of participants, up from $412 times the number of participants.

New due date for small plans. The due date transition rule for small plans is now fully phased in. That means small plans are now subject to the same due dates as other plans. In general, the 2015 due date for a calendar-year plan is Oct. 15, 2015.

New (optional) contact information. Plans that prefer the phone number shown on the PBGC’s “Is my Pension Insured?” web page be a number other than that of the plan administrator, may now provide an alternative phone number for that purpose.

New questions on risk transfer activities. Information about the number of former employees involved in certain recent risk transfer activities (i.e., annuity purchases and lump sum windows) now must be reported. Because the reporting requirement for 2015 applies to a much longer period than for subsequent years, reasonable estimates may be reported instead of exact counts.

Change in certification procedures for uploaded filings. In prior years, the person responsible for uploading was permitted to do so before the plan administrator had manually signed a hard copy of the premium data generated by the private sector software. Starting with 2015 filings, to ensure the filing has been certified by the plan administrator, the uploader must wait until the manual certification has been done. If the enrolled actuary is also certifying manually, the same rule applies regarding the actuarial certification. After the filing is uploaded, the My PAA generated confirmation number must be written on the certified paper copy.

Additional guidance re: small plan lookback rule. PBGC approval is required to start using the lookback rule in 2015 after opting out in 2014, and, with limited exceptions, to opt out of the lookback rule starting with 2015. The instructions have been expanded to clarify the exceptions and provide information on how to request approval.

The PBGC welcomes public comments on the form and instructions, which must be submitted to the Office of Management and Budget (OMB) by Feb. 11, 2015. Comments should be sent to the Office of Information and Regulatory Affairs, Office of Management and Budget, Attention: Desk Officer for the Pension Benefit Guaranty Corporation, to OIRA_DOCKET@omb.eop.gov.