Request a Proposal

PBGC Proposed Filing Changes

The PBGC has proposed changes to pension funding reporting to capture information from larger plans that currently receive a waiver on filing Section 4010. Plans over 80% funded or with a funding gap of less than $15 million have been able to obtain this waiver. Now the PBGC is concerned that plans whose funded status appears inflated, thanks to MAP-21 and HATFA rules for actuarial reporting, are skirting the purpose for 4010 filings for underfunding, and presenting a risk to the overburdened insurance program. The PBGC is proposing using an aggregate number of 500 participants to limit the waiver, and is currently seeking public comment. In a separate appeal earlier this year, the PBGC requested additional filing information about lump-sum and annuity purchase risk transfers, which reduce the premiums paid to the PBGC and make projections of its financial situation difficult.