Based on the information, the agency said it is considering future multiemployer plans compliance projects. EPCU is considering a follow up project to determine why multiemployer defined benefit (DB) plans with scheduled rehabilitation or funding improvement plans either did not report their scheduled progress on the certifications or are not making progress (for plans that reported “not making progress”).
Multiemployer DB plans must certify their actuarial status annually. This annual actuarial certification is due by March 31 for a calendar year plan, or 90 days after the beginning of the plan year for a fiscal year plan. Plan sponsors who fail to provide the certification on time may be subject to a penalty of up to $1,100 per day.
In other projects, the agency looked at sponsors who filed a Form 5500-series return indicating they were a multiemployer DB plan but did not provide an actuarial certification, and Form 5500 returns for plans it believed had incorrectly indicated they were multiemployer DB plans. The majority of cases in both projects were resolved.More information is here.