Groups Recommend Changes to PBGC's Premium Proposal

In July, the agency released a proposal to amend its regulations on Premium Rates and Payment of Premiums to simplify due dates, coordinate the due date for terminating plans with the termination process, make conforming and clarifying changes to the variable-rate premium rules, provide for relief from penalties, and make other changes (see “PBGC Proposes Premium Changes”).

The American Society of Pension Professionals & Actuaries (ASPPA), along with its sister organization, the ASPPA College of Pension Actuaries (ACOPA), recommended the PBGC “extend the uniform due date to new and newly covered plans, provide transition year relief for small plans that will be required to make two premium payments in one calendar year, and extend the ability to file an estimated premium to plans of any size.”

The ERISA Industry Committee (ERIC) also submitted comments on the proposal to PBGC. In its letter, ERIC stated its support for both the change to the premium due date for large plans and the lowering of the self-correction penalty cap. However, ERIC said that it believes, “the PBGC should not apply loading factors to premiums for plans that are at-risk.”

The full text of the ASPPA comments can be downloaded here. The full text of the ERIC comments can be found here.

The full text of the PBGC proposal can be found here.