2009-12-18
On November 23, 2009, the Pension Benefit Guaranty Corporation (PBGC) published a proposed rule which would make sweeping changes to the reportable event requirements under ERISA Section 4043.
Certain changes to the reportable event requirements were necessary due to the fact that the Pension Protection Act of 2006 (PPA) changed other PBGC-related calculations such as the variable rate premium. However, the PBGC proposed many other significant changes as well.
The proposed rule would eliminate most of the PBGC's automatic waivers and nearly every filing extensions allowed under existing rules and guidance. Additional information would need to be reported for every reportable event as well. In addition, two new reportable events would be added under the proposed rule to address plans with a low adjusted funded target attainment percentage ("AFTAP") and plans in which an asset transfer is made to a retiree health account.
This proposed rule is discussed in further detail in the Hewitt bulletin linked to at right. Included in the bulletin is a summary of the proposed changes to reporting waivers and extensions for each of the post-event reportable events and the advance reporting requirements.
Additional information:
Full text of the proposed rule on reportable events
Technical Update 09-4
Proposed draft reportable event forms and instructions:
Form 10 and Instructions
Form 10 Advance and Instructions
Form 200 and Instructions
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