Keep PBGC Premium Filings Timely and Accurate!

The Pension Benefit Guaranty Corporation (PBGC) on Sept. 16 issued an updated list of reminders intended to help plans keep their premium filings timely and accurate.

The list includes these pointers from the PBGC:

• For plan years starting in 2015, small plans are subject to the same normal due date rules as all other plans. For example, a small plan with a plan year commencing (PYC) date of Jan. 1, 2015 now has a due date of Oct. 15, 2015. Further details are in the “When to File” section of the 2015 premium instructions.

• For plan years starting in 2014, the transition due dates for small plans still apply. For example, a small plan with a PYC date of Dec., 2, 2014 has a normal due date of Feb 16, 2016. Further details are in the “When to File” section of the 2014 premium instructions.

• Take an inventory of the plans you are responsible for and take appropriate actions to ensure that filings are made timely and accurately (e.g., review each plan’s online account history). We expect high filing activity leading up to Oct. 15, 2015 (many plans have an October due date), so please file as soon as practicable.

• Be sure to use only the current Premium Payment Addresses for checks and electronic payments made outside of My PAA. Note that as of Oct. 1, 2015, any payments or mail sent to the previous JPMorgan addresses will be returned to the sender and could result in late payment penalties.

• For small plans that had the opportunity to opt out of the lookback rule in the past but chose not to, PBGC permission is required to opt out. Conversely, if a plan opted out of the lookback rule for 2014, and now wants to use the lookback rule, PBGC permission is required. The request must be emailed to [email protected] at least 60 days before the due date. Further details are in the “How to Determine Unfunded Vested Benefits” section of the 2015 premium instructions.

To help plans keep current and to file timely, the PBGC recommends signing up to receive monthly practitioner filing reminder emails for the months identified via the following link: http://www.pbgc.gov/prac/pg/other/practitioner-filing-reminders.html.

For answers to questions or to obtain assistance (e.g., if a My PAA account is locked or to deactivate a My PAA account because it is no longer needed), the PBGC recommends contacting one of its premium representatives at [email protected] or 1-800-736-2444; select the “premium” option.