DB Plan Sponsors Must Include More Information in Reportable Events Filings

The Office of Management and Budget (OMB) has approved changes to reportable events filings to the Pension Benefit Guaranty Corporation (PBGC) for defined benefit (DB) plans.

Last October, the agency requested that the OMB approved continued collection of reportable events filings, with some changes. The OMB has approved that all reportable events filings include controlled group information, company financial statements, and the plan’s actuarial valuation report. Currently there are five reportable events where some or all of that information isn’t required. All three types of information would be added to two of these events (‘‘Active Participant Reduction’’ and ‘‘Distribution to a Substantial Owner’’). One type of information would be added to two events (‘‘Transfer of Benefit Liabilities’’ and ‘‘Change in Contributing Sponsor or Controlled Group’’), and two types to one event (‘‘Extraordinary Dividend or Stock Redemption’’). The agency says the additional information is needed to help it determine a defined benefit (DB) plan sponsor’s ability to continue to maintain its DB plan.

Section 4043 of the Employee Retirement Income Security Act (ERISA) requires DB plan administrators and plan sponsors to report certain plan and employer events to the PBGC. The reporting requirements give agency notice of events that may indicate plan or employer financial problems. In 2015, the agency issued final rules which provide most plan sponsors with increased flexibility to determine whether a waiver from reporting will apply.