Changes Soon Due for Multiemployer Plans

Expanded annual actuarial certifications for multiemployer plans are due March 31 for calendar year plans.

The Multiemployer Pension Reform Act of 2014 (MPRA), enacted on December 16, 2014, revised the annual funding certification requirements for multiemployer plans.

The revisions generally apply to certifications for 2015 and subsequent plan years. The Internal Revenue Service (IRS) reminds plan sponsors that for calendar year plans, the 2015 certification is due by March 31.

MPRA also amended certain provisions of the Pension Protection Act of 2006 (PPA) by:

  • Making permanent the annual requirement to certify a plan’s funding zone: Before MPRA was passed, the annual certification requirement was scheduled to “sunset” on or after December 31, 2014.
  • Allowing for election of Critical status: Plans projected to be in Critical status in any of the succeeding five plan years may elect to be in Critical status in the current plan year. Plans may bypass Endangered status by making this election.
  • Changing rules for emergence from Critical status: This was amended to include a condition for projected insolvency and special rules for plans with automatic amortization extensions.

MPRA added a new zone status available for a plan actuary’s annual certification and added special rules allowing a plan to be treated as being in a particular zone when, before enactment, the plan would have been in a different zone.

More information about the new zone and special rules is here.