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Compliance October 16, 2026
PBGC Proposes Reporting Requirements for Multiemployer Plans With SFA Funds
Plan sponsors would be required to submit more data about missing participants and investment decisions.
Reported by
Emily Boyle
The Pension Benefit Guaranty Corporation today published proposed additional information requirements for multiemployer defined benefit plans receiving special financial assistance. The new requirements would expand the scope of information that recipient plans must file as part of their annual statement of compliance to include documentation of plan investment policies and their procedures for locating missing participants.
The Special Financial Assistance Program was enacted in 2021 as part of the American Rescue Plan Act. Administered by the PBGC, the program was intended to aid severely underfunded multiemployer defined benefit plans by ensuring their solvency through 2051. Upon approval of an SFA application, the PBGC provides a lump-sum payment to an eligible plan in an amount projected to enable the plan to pay full plan benefits through that year.
Under the proposal, published in the Federal Register on October 16, plans that received special financial assistance would be required to submit documents that explain how their investment decisions are made and monitored. The documents would include investment policy statements, investment guidelines, asset allocation policies, committee charters and other governing documents related to the management of plan assets.
The PBGC also proposed new information requirements related to missing participants. Plans that received special financial assistance would be required to provide available data for participants who may have lost contact with the plan, as well as documentation describing the procedures used to locate them.
“Oversight and compliance of the SFA program is important for everyone involved, but it has to be done in a reasonable way,” wrote Susan Boyle, Segal’s multiemployer retirement practice leader and a senior vice president, in an email. “Any additional items that are requested from plan sponsors should be pragmatic.”
The proposed revisions are open for public comment through December 15.