PBGC 2020 Premium Package Doesn’t Reflect CSEC Changes

Connecticut Enacts Paid Family and Medical Leave

The Pension Benefit Guaranty Corp. has issued its final premium payment instructions for 2020. The package incorporates changes published in the draft instructions issued last October, including PBGC’s position that the merger of a larger plan into a smaller plan is not de minimis and therefore doesn’t qualify for the special de minimis treatment for flat-rate premiums. 

The final package doesn’t reflect recent changes made by the Setting Every Community Up for Retirement Enhancement (SECURE) Act, enacted Dec. 20 with a government spending package (PL 116-94). The SECURE Act reduces PBGC premiums for cooperative and small-employer charity (CSEC) plans, effective for plan years beginning after Dec. 31, 2018. PBGC will issue separate CSEC guidance at a later date.

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Margaret Berger
by Margaret Berger

Partner, Mercer’s Law & Policy Group

Brian J. Kearney
by Brian J. Kearney

Principal, Mercer’s Law & Policy Group

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