Just-released PBGC premium filing instructions reflect few changes for 2019. The revised instructions include the premium rates in effect for 2019, provide some detail regarding PBGC's new disaster relief procedures, and include an expanded list of common filing errors. The instructions also explain how a plan sponsor may manually certify a premium filing. PBGC anticipates it will be ready to accept 2019 filings soon.
The 2019 instructions reflect the premium rates in effect for 2019 (also available in Mercer Select Intelligence's Quick Benefit Facts for 2019):
PBGC expanded the "When to File" section to reflect changes to its procedures regarding disaster relief. When IRS extends certain deadlines for taxpayers affected by major disasters, PBGC now automatically extends several of its own filing deadlines, including those for premium filings, until the end of the IRS's relief period. The instructions remind plan sponsors that qualify for disaster relief to notify PBGC before the end of the relief period. PBGC also suggests that affected sponsors may wish to notify PBGC via email in advance of submitting the delayed filing, to avoid getting a late-filing notice.
The list of common filing errors in Appendix 4 has been expanded to include entering incorrect information for a final short plan year. Some plans that qualify to pay a prorated premium have submitted filings with inconsistent data — for example, indicating that the plan year begins on Jan. 1 and ends on Dec. 31, but also that the premium was prorated for a short plan year. Such inconsistencies could trigger inquiries or invoices. The instructions also remind plan sponsors that short plan years created as the result of a midyear merger or consolidation aren't eligible for premium proration.
The instructions also:
For a comprehensive overview of PBGC's premium filing requirements, see Mercer Select Intelligence's updated guide to PBGC premiums for single-employer pension plans. The guide is available to US Wealth & Investments premium members.