Sibson Consulting Compliance Alert notes that these increases are in addition
to increases introduced by the 2012 Moving Ahead for Progress in the 21st
Century Act (MAP-21). Since premiums do not fund plan benefits or increase a
plan’s funded status, plans sponsors may
take steps to minimize the premiums payable, similar to taking step to avoid taxes.
Lawrence, senior vice president and national retirement practice leader at
Sibson in New York, says the PBGC is walking a fine line. “The agency has, by
its own calculation, raised premiums because it has an unfunded liability,” he
tells PLANSPONSOR. “If it raises them too much, employers will start to take
actions to reduce their premium base, for example, by taking actions to get
folks out of the plan.”
This seems counterintuitive to the PBGC’s goal to encourage
and preserve DBs, Lawrence adds, and “if [the agency] continues to raise premiums, the
premium becomes material, and if premiums become onerous, employers will end
plans and there will be no premiums.”
year, the PBGC variable-rate premium is 1.4% of a plan’s unfunded vested liability,
going up to at least 2.4% in 2015 and 2.9% in 2016, with indexing thereafter.
For an underfunded plan, increasing pension plan contributions above amounts
previously contemplated is the surest way to reduce the amount of the PBGC variable-rate
premium payment, according to the Sibson Compliance Alert.
The company notes
that making additional pension contributions generally provides a tax deduction
and tax-free accumulation of investment earnings. “If an employer has cash
lying around, why not put it into the plan; they will have to put cash in the
plan eventually, so why not save on premiums?” Lawrence says.