Comprehensive Premium Filing

Instructions for 2024 Plan Years
Contents

Introduction and What’s New..................................................................................................................1

Who Must File ..........................................................................................................................................3

When to File .............................................................................................................................................5

How to File ...............................................................................................................................................9

How to Count Participants.....................................................................................................................10

How to Determine Unfunded Vested Benefits......................................................................................14

Premium Proration.................................................................................................................................22

Spinoffs, Mergers and Consolidations...................................................................................................25

Data to be Submitted.............................................................................................................................31

Description of Data Elements ................................................................................................................36

Late Payment Charges............................................................................................................................50

Correcting Errors, Credit Balances and Reconciling Estimates..............................................................53

Recordkeeping Requirements and PBGC Audits....................................................................................56

Appendix 1 – Definitions........................................................................................................................57

Appendix 2 – Contact Information.........................................................................................................61

Appendix 3 – Common Filing Errors.......................................................................................................62

Appendix 4 – Special Rule for CSEC Plans..............................................................................................65

Appendix 5 – Paperwork Reduction Act Notice.....................................................................................66
Introduction and What’s New

Page 1

Introduction

Payment of premiums to the Pension Benefit Guaranty Corporation (PBGC) is required by sections 4006 and 

4007 of the Employee Retirement Income Security Act of 1974 (ERISA), and PBGC’s Premium Regulations (29 

CFR Parts 4006 and 4007). 

There are two kinds of annual premiums: Flat-rate Premium, which applies to all plans, and Variable-rate 

Premium (VRP), which applies only to Single-employer Plans.

Every covered plan under ERISA section 4021 must make a premium filing each year. The due dates are 

described in the “When to File” section.

Electronic filing is mandatory for all plans. My Plan Administration Account (My PAA) is a secure web-based 

application that enables pension plan professionals to electronically submit premium filings to PBGC in 

accordance with PBGC’s regulations. Electronic filings may be prepared using My PAA’s data entry screens or 

with compatible private-sector software. See “How to File” section for more information. For more information 

on e-filing options, see Appendix 3.

This document provides information for plans paying premiums for plan years beginning in 2024, including 

instructions for each data element that must be reported.

Plan years beginning before 2024

If you are filing for a previous year or amending a filing for a previous year, with the exception of contact and 

payment information which may have changed, you must follow the instructions for that year (available from 

the “Premium Filing” web page).

Defined terms

Appendix 1 provides definitions for terminology used in this document. In general, the defined terms are 

capitalized to signal the reader to refer to Appendix 1 for more information. The convention of capitalizing the 

defined terms is not followed for a few defined terms such as “participant,” “we,” “you,” and “your.” In addition, 

this convention is not followed on the illustrative form (i.e., in the “Data to be Submitted” section). 
Introduction and What’s New

Page 2

What’s New 

The filing requirements for 2024 are almost identical to the filing requirements for 2023. Here are the key 

changes to note for 2024:

 Changes in premium rates:

– Single-employer plans other than CSEC plans: 

o The Flat-rate Premium is $101 per-participant, up from $96.

o The cap on the Variable-rate Premium is $686 per person, up from $652.

Note that because legislation enacted in 2022 eliminated indexing on the variable rate premium rate, the 

2023 rate of $52 per $1,000 of unfunded vested benefits remains unchanged.0F

1

– Multiemployer Plans: The Flat-rate Premium is $37 per-participant, up from $35. Multiemployer plans do 

not pay Variable-rate Premiums.

Premium rates for CSEC plans are not indexed, and thus those rates have not changed.

 The Premium Customer Service email address has changed from pbgc_premiums@custhelp.com to

premiums@pbgc.gov. Emails sent to the old address will be forwarded to the new mailbox.

Common filing errors

 Incorrect plan identifying information (e.g., effective date)

 Sending payment by ACH or Fedwire without properly identifying plan (e.g., EIN / PN / PYC) 

 Lookback Rule inconsistencies (Small Plans only)

 Required explanation for certain amended filings missing or does not adequately explain why 

the premium amount changed.

 Reporting incorrect “plan year” information for final Short Plan Years

 Disregarding warning messages during submission process.

Appendix 3 provides detailed information about these errors.

1 Sec. 349 of Act of 2022, Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117–328 (Dec. 29, 2022), 

commonly called SECURE 2.0.
Who Must File

Page 3

All covered plans must file

The Plan Administrator of each pension plan covered under ERISA section 4021 is required to annually file the 

prescribed premium information and pay the premium due in accordance with PBGC’s Premium Regulations and 

instructions.

Most private-sector defined benefit plans that meet tax qualification requirements are covered.0F1F

2 If you are 

uncertain whether your plan is covered, we recommend you promptly request a determination by submitting a 

coverage determination form, available on PBGC’s “Pension Insurance Coverage” web page.

If your plan is covered, you must submit a premium filing even if:

 No premium is owed;

 The plan year is less than 12 months (i.e., a Short Plan Year); or

 The plan was not covered by PBGC for the entire plan year (i.e., a Short Coverage Year).

In certain specified situations, plans with Short Plan Years or Short Coverage Years pay a prorated premium. See 

“Premium Proration” section.

Note for Plans with Retroactive Effective Dates — PBGC coverage begins on the plan’s effective date, regardless 

of when the plan is adopted. Thus, a 2024 filing is required for a plan with an effective date in 2024, even if that 

plan isn’t adopted until after 2024 and regardless of whether a premium is owed for 2024.

One Plan or More Than One?

If several unrelated employers participate in a program of benefits wherein the funds attributable to each 

employer are available to pay benefits to all Participants (i.e., a Multiemployer or Multiple-employer Plan), the 

Plan Administrator must file and pay premiums for the plan as a whole. If separate plans are maintained for 

different groups of employees, regardless of whether each is maintained by the same employer or by employers 

that are part of the same controlled group, the Plan Administrator(s) must file and pay premiums separately for 

each plan.

2 A church plan that makes an irrevocable election under IRC § 410(d) to be subject to certain IRC § 401(a) tax qualification requirements 

(e.g., participation, vesting, funding) is covered by PBGC only if it chooses to be covered and notifies PBGC accordingly. See PBGC’s 

“Pension Insurance Coverage” web page for information about this requirement.
Who Must File

Page 4

When Filing Obligation Ceases

You must continue to make premium filings and pay premiums through and including the plan year in which any 

of the following occurs:

 A trustee is appointed for the plan under ERISA section 4042;

 The plan ceases to exist because all of its assets and liabilities were transferred to one or more other plans in 

a Merger or Consolidation;

 The plan ceases to be a covered plan under ERISA section 4021;1F2F

3 or

 Plan assets are distributed in satisfaction of all Benefit Liabilities pursuant to a standard termination.2F3F

4

The following examples illustrate when the filing obligation ceases:

Example 1 – A calendar-year plan terminates in a standard termination with a termination date of September 

29, 2023. On April 6, 2024, assets are distributed in satisfaction of all Benefit Liabilities. The Plan Administrator 

must file and make the premium payments for the 2023 and 2024 plan years. There is also an obligation to file a

post-distribution certification (Form 501) as part the standard termination process. See § 4041.29 for additional 

information.

Example 2 – A plan with a plan year beginning July 1 and ending June 30 terminates in a distress termination 

with a termination date of April 27, 2024 (i.e., during the plan year beginning July 1, 2023). On July 6, 2024, a 

trustee is appointed to administer the plan under ERISA section 4042. Because a trustee was not appointed 

until after the beginning of the 2024 plan year (i.e., the plan year July 1, 2024 – June 30, 2025), a premium filing 

and payment must be made for this plan for the 2024 plan year.

3 If you believe coverage has ceased, submit a request for a coverage determination as soon as possible. A form for this purpose is 

available on PBGC’s “Pension Insurance Coverage” web page.

4 The due date for the final filing may be accelerated for the plan year in which assets are distributed in satisfaction of Benefit Liabilities 

pursuant to a standard termination. See “When to File” section). 
When to File

Page 5

Introduction

This section describes when premium filings are due. A filing includes both the submission of required data and 

the payment of any required premium. In general, if a filing is not made by the due date, late payment charges 

will apply. Late payment charges include both interest charges and penalty charges. See “Late Payment Charges” 

section for more information on the ramifications of missing a deadline.

Normal Premium Due Date

In most cases, premium filings are due on the Normal Premium Due Date, (i.e., the 15th day of the 10th full 

calendar month in the plan year).3F4F

5 If the Normal Premium Due Date falls on a Saturday, Sunday or Federal 

Holiday,4F5F

6 the due date is automatically extended to the next business day.5F6F7 The special situations for which 

premiums are due on a date other than the normal premium due are summarized in the next section.

The following table shows the Normal Premium Due Dates for plan years beginning in 2024:

2024 Normal Premium Due Dates

Date Premium

Payment

Year Begins

Normal

Premium Due

Date

Date Premium 

Payment

Year Begins

Normal

Premium Due 

Date

1/1/2024 10/15/2024

1/2/2024 - 2/1/2024 11/15/2024 7/2/2024 - 8/1/2024 5/15/2025

2/2/2024 - 3/1/2024 12/16/2024* 8/2/2024 - 9/1/2024 6/16/2025*

3/2/2024 - 4/1/2024 1/15/2025 9/2/2024 - 10/1/2024 7/15/2025

4/2/2024 - 5/1/2024 2/18/2025* 10/2/2024 - 11/1/2024 8/15/2025

5/2/2024 - 6/1/2024 3/17/2025* 11/2/2024 - 12/1/2024 9/15/2025

6/2/2024 - 7/1/2024 4/15/2025 12/2/2024 - 12/31/2024 10/15/2025

* The Normal Premium Due Date falls on a Saturday, Sunday or Federal Holiday, so the date shown above is the first 

business day following the actual due date.

5 The due date is the 15th day of the 10th full calendar month that begins on or after the first day of the Premium Payment Year. In 

situations involving a Short Plan Year, this due date may not be “in the plan year.” 6 This extension does not apply to state or local holidays such as Patriots Day in Massachusetts or Emancipation Day in the District of 

Columbia. 7 See “Late Payment Charges” section for information on how late charges are determined if payment is made after an automatically 

extended due date.
When to File

Page 6

Due Date for Special Situations

In the situations noted below, premiums may be due on a date other than the Normal Premium Due Date:

 The plan is a New or Newly Covered Plan, 

 All assets are distributed during the Premium Payment Year pursuant to a standard termination,

 The plan is eligible for PBGC disaster relief, or

 The plan year changed since last year.

The due dates for these situations are described below. For all of these situations, if the adjusted due date falls 

on a Saturday, Sunday or Federal Holiday, the due date is automatically extended to the next business day.

New and Newly Covered Plans

In some cases, these first-time filers cannot have their filings ready by the Normal Premium Due Date. For 

example, consider a calendar year plan that is adopted November 1st with an effective date retroactive to 

January 1. Because the plan was adopted after the Normal Premium Due Date , a later due date is warranted.

This rule applies even if the New Plan was created as the result of a mid-year Spinoff from another plan.

To accommodate such plans, the due date for New and Newly Covered Plans is the latest of:

 The Normal Premium Due Date,

 90 days after the date of the plan’s adoption,

 90 days after the date on which the plan became covered by Title IV of ERISA, or

 In the case of a Small Plan that is also a Continuation Plan, 90 days after the UVB Valuation Date.

These rules are illustrated in the following examples:

Example 1 – Plan A, a calendar-year plan, was adopted August 1, 2024 with a retroactive effective date of 

January 1, 2024. Plan A is not a Continuation Plan or a Small Plan. The due date for Plan A’s first premium filing is 

October 30, 2024 (90 days after August 1, 2024) because that date is later than the Normal Premium Due Date 

(October 15, 2024).

Example 2 – The situation for Plan B is identical to Plan A (see Example 1) except that the plan was adopted one 

month earlier (i.e., July 1, 2024). The due date for Plan B’s first premium filing is October 15, 2024, the Normal 

Premium Due Date, because that date is later than 90 days after the adoption date (September 29, 2024).

Example 3 — The situation for Plan C is identical to Plan A (see Example 1) except that the retroactive effective 

date was one year earlier (i.e., January 1, 2023). Because the effective date is in 2023, a premium filing is due for 

the 2023 plan year. That filing is due October 30, 2024 (90 days after the adoption date) because that date is 

later than the Normal Due Date for the 2023 plan year.

Because Plan C is not considered a New Plan for 2024, the regular due date rules apply which means the 2024

premium filing is due October 15, 2024 (two weeks before the 2023 premium is due).
When to File

Page 7

Example 4 – A professional service employer maintains Plan D, a calendar plan year plan. From plan inception

through September 1, 2024, Plan D never had more than 25 active Participants, and was not a covered plan 

under ERISA section 4021. On September 1, 2024, a few employees were hired and became covered by the plan 

resulting in a total active Participant count of 26 and therefore, the plan became a covered plan on that date.

Plan D will continue to be a covered plan regardless of how many active Participants the plan has in the future.

Note that the Premium Payment Year begins on January 1, 2024, even though the plan did not become covered 

until after that date. The due date for the plan’s first premium filing is November 30, 2024 (90 days after 

September 1, 2024) because the date is later than the Normal Premium Due Date (October 15, 2024).

See “Spinoffs, Mergers, and Consolidations” section for additional examples of how these types of transactions 

affect due dates.

Assets Distributed Pursuant to a Standard Termination

For the Premium Payment Year in which all plan assets are distributed pursuant to a standard termination, it is

possible that the employer will be out of business or plan records and personnel will not be available by the 

Normal Premium Due Date. To streamline the final premium payment with the other activities related to a 

standard termination, the due date for a plan in this situation is the earlier of: 

 The Normal Premium Due Date (i.e., the date premiums would have been due had the plan not been 

terminated), or

 The date when the post-distribution certification6F7F

8 is filed with PBGC.

Plans Affected by Certain Disasters

When the IRS grants relief to certain taxpayers that are unable to meet filing deadlines because of a major 

disaster (e.g., a hurricane), the premium due date for plans in the IRS-designated disaster area is extended to 

the end of the relief period.

If your plan qualifies for disaster relief, you must notify PBGC on or before the end of the relief period. In 

general, this notification is done as part of the Comprehensive Premium Filing.7F8F

9. However, if you anticipate it 

will be difficult to submit the Comprehensive Premium Filing by the end of the relief period, you may notify us 

by email. See PBGC’s Disaster Relief Announcement for more information.

When an expected premium filing is not received timely, PBGC typically sends a “past due filing notice” to the 

plan administrator. We appreciate that receiving such notices can be disconcerting in situations where the filer 

is eligible for disaster relief. But, until PBGC receives a filing or email indicating that your plan is subject to an 

extended due date because of disaster relief, PBGC does not know that there is a good reason the filing has not

yet been submitted.

If your plan is eligible for disaster relief, you can stop these notices from being sent simply by letting PBGC know 

that your plan is eligible for disaster relief. To do so, just send an email in advance of the normal due date

to premiums@pbgc.gov identifying the plan, the disaster, the applicable IRS Notice number, etc. 

8 The post-distribution certification (Form 501) is a document required to be submitted to PBGC as part the standard termination 

process. See § 4041.29 for additional information.

9 See line 20 and box at the top of the first page of the illustrative form in the “Data to be Submitted” section. 
When to File

Page 8

Plans Changing Plan Years

For a plan that changes its plan year, the filing due dates for the short year are unaffected by the change in plan 

year. However, for the first plan year under the new cycle, the due date is whichever is later:

 The Normal Premium Due Date, or

 30 days following the date on which a plan amendment changing the plan year was adopted. 

The following examples show the due dates for plans changing plan years:

Example 1 – By plan amendment adopted on December 1, 2024, a plan changes from a plan year beginning 

January 1 to a plan year beginning June 1, effective June 1, 2024. This results in a Short Plan Year beginning 

January 1, 2024 and ending May 31, 2024. Premiums for the Short Plan Year are due October 15, 2024, the 

Normal Premium Due Date. 

For the plan year beginning June 1, 2024, the premiums are due by the Normal Premium Due Date (March 17, 

2025) because that is later than 30 days after the date the plan amendment changing the plan year was adopted 

(December 31, 2024).

Example 2 – By plan amendment adopted on January 8, 2025, and retroactively effective to April 1, 2024, a plan 

changes from a plan year beginning on March 1 to a plan year beginning on April 1, resulting in a Short Plan Year 

(March 1, 2024 - March 31, 2024). For that Short Plan Year, the premium is due December 16, 2024. For the 

plan year beginning April 1, 2024, the due date is February 7, 2025, 30 days after the adoption of the plan 

amendment changing the plan year, because that is later than the Normal Premium Due Date (January 15, 

2025). 

Additional Information

You can find detailed rules about filing due dates in PBGC’s premium payment regulation (29 CFR Part 4007). 
How to File

Page 9

General

To make a complete premium filing, you must report certain required data and submit any required premium 

payment by completing and submitting a Comprehensive Premium Filing.

A list of the data that must be reported is included in the “Data to be Submitted” section. For simplicity, the 

required data elements are shown in a traditional “form” format. The purpose of the “form” is to provide a 

comprehensive list of data that must be submitted electronically. These instructions are written as if they 

related to the illustrative form (see “Description of Data Elements” section). The “form” is for illustrative 

purposes only.

Filing Method

Premium filings are submitted electronically through PBGC’s e-filing application, My Plan Administration 

Account (My PAA).

You may prepare the filing directly using My PAA’s data entry screens. Alternatively, you may use approved 

private-sector software to prepare a filing and then “upload” the filing via My PAA. Approved private-sector

software will convert your filing to an “XML” file that meets PBGC specifications. 

Depending on how you choose to prepare electronic filings (My PAA data entry screens or private-sector 

software), the order in which the questions are asked may differ from the order shown on the forms. In 

addition, in some cases, the software may perform certain calculations instead of requiring that you manually 

enter each required data element. 

The “Online Premium Filing (My PAA)” section of PBGC’s website provides detailed, and often more up to date, 

information about My PAA.

Paying Premiums 

Although e-filing of premium information through My PAA is mandatory, premium payments may be made 

either within My PAA or outside of My PAA. If you choose to pay within My PAA, your payment will be made

by an electronic funds transfer using Automated Clearing House (ACH). If you pay outside of My PAA, you may 

pay by electronic funds transfer (ACH or Fedwire), paper check or on-line via www.pay.gov. Pay.gov is a free, 

and user-friendly Federal website from which you can make secure electronic payments directly to many Federal 

Agencies, including PBGC. We recommend using Pay.gov to minimize the potential for errors (e.g., incorrect 

account numbers).

Note re: debit blocks - If you are sending payment electronically, be sure to provide the PBGC Company ID to 

your financial institution before you submit your payment so they may authorize PBGC to debit your account.

Without this authorization, your financial institution may reject the processing of your payment. A debit block is 

the most common reason for failed ACH payments, and the most common reason late premium payment

penalties are assessed.

Currently, PBGC has two Company ID numbers, one for payments made within My PAA, and one for payments 

made outside of My PAA. Please refer to the payment instructions in My PAA or on PBGC’s website for up-todate information.

Additional information on payment options is included on the Premium Filing Payment & Instructions web page.
How to Count Participants

Page 10

General

Plan Participants must be counted because Flat-rate Premiums are based on the number of Participants, as are 

both caps on the Variable-rate Premium (MAP-21 Cap and Small Employer Cap). In addition, the number of 

Participants affects whether Variable-rate Premiums are based on current or prior (i.e., “lookback”) year 

measurements. The date on which Participants are counted is called the “Participant Count Date.”

Participant Count Date

In general, the Participant Count Date is the last day of the Prior Premium Payment Year. However, in the 

scenarios described below, it is the first day of the Premium Payment Year:

 The plan is a New Plan

 The plan is a Newly Covered Plan (regardless of whether the plan was covered under ERISA section 4021 on 

that date).

 With respect to a Spinoff:

- The plan is the Transferor Plan, 

- The Spinoff is effective on the first day of the Transferor Plan’s Premium Payment Year, and

- The Spinoff is not De Minimis.

 With respect to a transaction in which a plan transfers some, but not all of its assets into another plan:

- The plan is the Transferee Plan,

- The transaction is effective on the first day of the Transferee Plan’s Premium Payment Year, and

- With respect to the Transferor Plan, the transfer (i.e., the Spinoff) is not De Minimis. 

 With respect to a Merger:

- The plan is the Transferee Plan,

- The Merger is effective on the first day of the Transferee Plan’s Premium Payment Year, and

- The Merger is not De Minimis, or the amount transferred to the Transferee Plan in conjunction with the 

Merger exceeds the value of the Transferee Plan’s assets immediately before the Merger (i.e., the 

transaction was structured such that the smaller plan was the surviving plan). 

The following examples illustrate the determination of the Participant Count Date. 

Example 1 – An ongoing plan changes its plan year from a calendar year to a plan year that begins June 1, 

effective June 1, 2024. The Participant Count Date for the:

 January 1, 2024 – May 31, 2024 plan year is December 31, 2023, 

 June 1, 2024 – May 31, 2025 plan year is May 31, 2024.

Example 2 – A new calendar-year plan is adopted February 20, 2024, retroactively effective as of January 1, 

2024. The Participant Count Date is January 1, 2024.

Example 3 – A new calendar-year plan is adopted January 1, 2024, effective April 1, 2024. The Participant Count 

Date is April 1, 2024.
How to Count Participants

Page 11

Example 4 – A calendar-year plan that was not a covered plan under ERISA section 4021 becomes covered on 

May 31, 2024. The first day of the Premium Payment Year is January 1, 2024, and the Participant Count Date is 

January 1, 2024.

See “Spinoffs, Mergers, and Consolidations” section for additional examples of how these types of transactions 

affect the Participant Count Date.

Participant

For premium purposes, “Participant” means an individual (whether active, inactive, retired, or deceased) with 

respect to whom the plan has Benefit Liabilities as of the Participant Count Date. Beneficiaries and alternate 

payees are not counted as Participants. However, a deceased Participant will continue to be counted as a 

Participant if there are one or more beneficiaries or alternate payees who are receiving or have a right to receive 

benefits earned by the Participant.

An individual is not counted as a Participant after an insurer makes an irrevocable commitment to pay all Benefit 

Liabilities with respect to the individual or after all Benefit Liabilities with respect to the individual are otherwise 

distributed. In addition, a non-vested individual is not counted as a Participant after:

 A deemed “zero-dollar cashout,”

 A one-year break in service under plan rules, or

 Death. 

Cashouts

If the plan has a separate cashout provision for zero benefits, terminated non-vested Participants are deemed to 

be cashed out as of the date specified in the deemed cashout provision or, if no date is specified, as of the 

employment termination date. If the plan provides that zero benefit amounts will be deemed to be paid as soon 

as possible, terminated non-vested Participants will also be deemed to be cashed out as of the employment 

termination date. 

If the plan does not have a separate cashout provision for zero benefits but does have a mandatory cashout of 

small benefit amounts (e.g., benefits $7,000 or less), terminated non-vested Participants are deemed to be 

cashed out in the same manner as terminated vested Participants. If the plan is silent as to the timing of actual 

cashouts of terminated vested Participants, the plan is deemed to read “as soon as practicable” and the 

terminated non-vested Participants are deemed to be cashed out immediately upon termination of 

employment. If the plan specifies a date as of which actual cashouts of terminated vested Participants take place 

(e.g., on the first day of the next month), that rule would also apply to deemed cashouts of terminated nonvested Participants. These rules do not apply if, despite plan language, the plan has an obvious pattern or 

practice of delaying distributions for long periods. 
How to Count Participants

Page 12

Example – Suppose a calendar-year plan provides that if a Participant terminates employment and the 

Participant’s vested benefit has a value of $7,000 or less, the plan will pay the vested benefit to the Participant

in a lump sum as of the first of the month following termination of employment. Suppose further that no plan 

provisions specifically address payment of benefits upon termination of employment by non-vested Participants. 

If a Participant with a non-vested accrued benefit terminates employment on December 15, 2023, the 

Participant will be included in the Participant Count as of December 31, 2023 (because the cashout is deemed to 

occur on January 1, 2024, the first of the month following termination of employment). If, as is typically the case 

for a calendar-year plan, the plan’s Participant Count Date for 2024 is December 31, 2023, a Flat-rate Premium 

must be paid for this Participant for 2024. 

Breaks in Service

A non-vested individual ceases to be a Participant for premium purposes when the individual incurs a one-year 

break in service under the plan. 

If the break in service occurs in a service computation period that coincides with the Prior Premium Payment 

Year, we treat the individual as not being a Participant for purposes of determining the premium for the 

Premium Payment Year.

Example 1 – A calendar-year plan with five-year vesting provides that a Participant who performs 500 or fewer 

hours of service in a service computation period incurs a one-year break in service as of the last day of the 

computation period. The plan also provides that the annual service computation period begins on the 

anniversary of a Participant’s date of hire. Consider an employee who was hired on December 1, 2018 and

terminates employment on February 1, 2023. Further assume that this Participant does not perform more than 

500 hours of service during the December 1, 2022 – November 30, 2023 computation period. This Participant

incurs a one-year break in service on November 30, 2023. Since the break occurred before December 31, 2023

(the Participant Count Date for the 2024 premium), the individual would not be included in the Participant 

Count for 2024.

Example 2 – A calendar-year plan provides that a Participant who performs 500 or fewer hours of service in a 

service computation period incurs a one-year break in service as of the last day of the computation period. The 

plan also provides that the annual service computation period is the calendar year. Consider a non-vested 

employee who does not perform more than 500 hours of service during the 2023 calendar-year computation 

period. This Participant incurs a one-year break in service on December 31, 2023. Although the break occurs on 

the Participant Count Date for the 2024 premium, the individual would not be included in the Participant Count 

for 2023.

Comparison to Form 5500 

The Participant Count for the Premium Payment Year and the number of Participants reported for item 6 of 

Form 5500 for the Prior Premium Payment Year (e.g., the 2024 premium filing and the 2023 Form 5500) are 

generally determined as of the same date (i.e., the last day of the Prior Premium Payment Year). However, the 

two counts may differ. For example:

 For premium purposes, individuals who are earning or retaining credited service but with respect to whom a 

plan has no Benefit Liabilities are not counted as Participants. But individuals who are earning or retaining 

credited service are considered to be Participants for purposes of item 6 of the Form 5500, even if the plan 

has no Benefit Liabilities with respect to them. 
How to Count Participants

Page 13

 There is a difference in the break-in-service rules that apply when counting Participants for premium 

purposes and for purposes of item 6 of Form 5500. For purposes of item 6 of Form 5500, whether a 

non-vested individual is excluded from the count because of a break in service depends upon the plan 

language; under the provisions of most plans, the instructions for item 6 would require that a separated 

non-vested individual be counted as a Participant until the individual has incurred five or more consecutive 

one-year breaks in service. For premium purposes, on the other hand, a non-vested individual is excluded 

from the count because of a break in service when the individual has incurred a one-year break in service 

under the terms of the plan.
How to Determine Unfunded Vested Benefits

Page 14

General

“Unfunded vested benefits” (UVBs) is the term used to describe the underfunding measure on which the 

Variable-rate Premium is based (i.e., the excess, if any, of the Premium Funding Target, over the fair market 

value of plan assets). This section describes how and when the Premium Funding Target and fair market value of 

plan assets are determined for this calculation. 

Note for CSEC plans – the instructions below relate to Single-employer plans other than CSEC plans. Appendix 4

provides information about where the special rules for CSECs override these instructions.

Which year’s UVBs

In general, Variable-rate Premiums are based on UVBs for the Premium Payment Year. However, Small Plans are 

subject to a Lookback Rule, under which the Variable-rate Premium for the Premium Payment Year is based on 

UVBs for the Prior Premium Payment Year - for example, under the Lookback Rule, the 2024 Variable-rate 

Premium is based on UVBs for 2023 (the Lookback Year).

The lookback rule first applied for 2014 plan years. At that time Small Plans were given automatic approval to 

permanently opt out of the Lookback Rule (i.e., to use current year UVBs to determine the Variable rate 

Premium). Most Small Plans chose to do so. Those plans must continue to use current year UVBs to determine 

the Variable-rate Premium unless and until they seek and receive permission from PBGC to start using the 

Lookback Rule in the future. Information about how to seek such permission is covered later in this “Which 

year’s UVBs” section.

New and Newly Covered Small Plans

The Lookback Rule doesn’t apply to New and Newly Covered Small Plans because such plans don’t have a 

covered prior year to look back to. So, special rules apply. If a New or Newly Covered Plan is Small and:

 Was created as the result of a non-De Minimis Spinoff or Consolidation (i.e., “Continuation Plans”), the 

Variable-rate Premium for the Premium Payment Year is based on UVBs for that same year. These plans do, 

however, get more time to complete their filings (see “When to File” section). 

 Is not a Continuation Plan, the plan is exempt from the Variable-rate Premium for its first year of filing. Note 

that such a plan could be either a newly established plan or a plan resulting from a De Minimis Spinoff. The 

exception applies in either case.

These plans will be permitted to opt out of using the Lookback Rule without first seeking PBGC permission, the 

first time the Lookback Rule would otherwise apply.

Opting out of the Lookback Rule Starting with 2024

 Not the first opportunity to opt out - If a Plan had the opportunity to opt out of the Lookback Rule in the 

past but chose not to, PBGC permission is required to opt out for 2024. See next page for information on 

how to seek such permission.

 First opportunity to opt out - If the 2024 plan year is the first year for which a plan has the opportunity to 

opt out of the Lookback Rule, the plan may do so without first seeking permission from PBGC. For example, 

permission to opt out is not required if:

– The plan was not a Small Plan for any year after 2014, but because of a decrease in Participant Count, is 

a Small Plan for 2024;
How to Determine Unfunded Vested Benefits

Page 15

– The plan was a New or Newly Covered Small Plan that was also a Continuation Plan for 2023 and was 

thus, required to use current year UVBs to determine its 2023 Variable-rate Premium;

– The plan did not have to calculate nor report UVBs for any year after 2014 because it was exempt from 

the Variable-rate Premium or eligible for the Small-employer Cap and chose to pay the cap and not 

report UVBs. 

Small Plans reporting UVBs for the first time are cautioned to be careful to ensure the data reported in the 

Variable-rate Premium section of the filing are entered correctly because if the reported UVB Valuation 

Date8F9F

10 is within the Premium Payment Year, we will expect all future filings to be completed using current 

year UVBs to determine the Variable rate- Premium.

Note for Small Plans with year-end valuation dates – It is not practical for a Small Plan with a year-end 

valuation date to opt out of the Lookback Rule. For example, consider a Small Plan with a calendar year plan 

year. Opting out of the Lookback Rule would mean measuring UVBs on December 31st, two and a half 

months after the October 15th due date.

Requesting permission to use (or not use) the Lookback Rule

As noted above, PBGC permission is required if:

 a Small Plan that had the opportunity to opt out of the Lookback Rule in the past but chose not to, wants to 

opt out starting with 2024, or

 a Small Plan that opted out of using the Lookback Rule in the past, wants to start using the Lookback Rule 

starting with 2024.

Such requests must be submitted at least 60 days before the due date using one of the following options:

 My PAA: Send a message via My PAA by selecting the “Submit Request” link from the Plan Details page, then 

selecting “Other Requests & Correspondence” and finally the “Request re: Lookback Rule” request type.

Submitting the request this way has many benefits (e.g., automatically generated confirmation email, ability 

to check the status of a request).

For more information about submitting requests via My PAA, see PBGC’s My PAA online demo web page.

 Email: Send an email to premiums@pbgc.gov with “Request re: Lookback Rule” in the subject line. If you do 

not receive an email acknowledgement within two business days, please call PBGC at 1-800-736-2444 or 

(202) 229-4242 (select option 2) to confirm that your request was received.

PBGC will review such requests based on the facts and circumstances and will grant such requests only for good 

cause in appropriate circumstances. PBGC will not grant requests made solely to reduce premiums.

If you do not receive a determination within 30 days of making the request, please call us at 1-800-736-2444, as 

you will need the determination to make a timely premium filing.

10 See line (7)(c)(3) of the illustrative form in the “Data to be Submitted” section.
How to Determine Unfunded Vested Benefits

Page 16

Measurement date

UVBs are measured on the funding valuation date (i.e., the measurement date for determining the minimum 

required contribution) for the applicable plan year (i.e., either the Premium Payment Year or the Lookback Year, 

depending on whether the Lookback Rule applies). Regardless of whether the Lookback Rule applies, this date is 

called the UVB Valuation Date to distinguish it from the Participant Count Date (see “How to Count Participants” 

section).

So, for plans using the Lookback Rule, the UVB Valuation Date is the valuation date used to determine the 

minimum required contribution (i.e., “the funding valuation date”) for the Lookback Year. For all other plans, the 

UVB Valuation Date is the funding valuation date for the Premium Payment Year.

Examples

The following examples illustrate these rules:

Example 1 – Plan A, a calendar year plan, is not a Small Plan and therefore, in accordance with ERISA 303 must 

have a beginning of year valuation date. Plan A’s Variable-rate Premium for 2024 is based on UVBs for 2024 (i.e., 

the Premium Payment Year) measured as of 1/1/2024. This result is not dependent on whether the plan is a 

Continuation Plan.

Example 2 – Plan B is a pre-existing Small Plan that did not opt out of the Lookback Rule in 2014 and to date has 

not submitted a request to PBGC regarding the Lookback Rule. Plan B has a calendar year plan year and a 

beginning of year valuation date. Plan B’s Variable-rate Premium for 2024 is based on UVBs for the plan year 

beginning in 2023 measured as of 1/1/2023.

Example 3 – Plan C is a New Small Plan with a calendar year plan year created as the result of a non-De Minimis

Spin-off on 1/1/2024 is therefore considered a Continuation Plan for 2024. Plan C has a beginning of year

valuation date. As a Continuation Plan, Plan C is not subject to the Lookback Rule for 2024 (because there is no 

prior year to look back to). That means UVBs are measured as of 1/1/2024.9F10F

11

Example 4 – Plan D is a pre-existing Plan with a calendar year plan year and a beginning of year valuation date.

Plan D had a Participant count greater than 100 for all years from 2017 through 2023, but due to attrition, its 

2024 Participant count is 98. Thus, Plan D is now subject to the Lookback Rule. That means Plan D’s Variable-rate 

Premium for 2024 is based on UVBs for the plan year beginning in 2023 (i.e., the “Lookback Year” measured as 

of 1/1/2023), the same UVBs that were used to determine the 2023 VRP. Alternatively, Plan D may opt out of 

the Lookback Rule, in which case, its Variable-rate Premium for 2024 will be based on UVBs for the plan year 

beginning in 2024 measured as of 1/1/2024.

11 Assuming the participant count remains below 100, Plan C will be subject to the Lookback Rule for 2025 unless Plan C chooses to opt 

out of using the Lookback Rule for 2024. If Plan C does not opt out, Plan C’s Variable-rate Premium for 2025 will also be based on UVBs 

for 2024 measured as of 1/1/2024.
How to Determine Unfunded Vested Benefits

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Premium Funding Target

The Premium Funding Target is the liability measure underlying the UVB calculation. It is determined the same 

way the funding target is determined under ERISA section 303 (minimum funding requirements) except that 

only vested benefits are included, and a special premium discount rate structure is used. With the exception of 

the discount rate, all other assumptions must be identical to those used to determine the minimum required 

contribution under ERISA section 303. In lieu of using the special premium discount rates, you may make an 

election (irrevocable for five years) to use smoothed discount rates, similar to, and in some cases identical to, 

the rates used to determine the minimum required contribution. Different terminology is used to describe the 

Premium Funding Target depending on whether this election is in effect. 

 Standard Premium Funding Target – This term describes the Premium Funding Target that applies unless the 

above-noted election is in effect. The discount rates used to determine the Standard Premium Funding 

Target are the ERISA section 4006(a)(3)(E)(iv)) segment rates for:

- In the case of a Small Plan using the Lookback Rule, the month before the month in which the Lookback 

Year begins.

- In the case of any other plan, the month before the month in which the Premium Payment Year begins.

The ERISA section 4006(a)(3)(E)(iv) segment rates are based on the same bond yields as used to determine 

the segment rates for the ERISA section 303 funding target. However, unlike ERISA 303 segment rates which 

are averaged over 24 months, the segment rates used to determine the Standard Premium Funding Target 

are not averaged. These “spot” segment rates are published by IRS each month and are also posted on 

PBGC’s “Interest Rates and Factors” web page.

 Alternative Premium Funding Target – This term describes the Premium Funding Target if the election 

described above is in effect. The Alternative Premium Funding Target is determined using the discount rates 

that would have been used to determine the ERISA section 303 funding target10F11F

12 for the Premium Payment 

Year (or, for a plan using the Lookback Rule, the Lookback Year) if not for the Interest Rate Stabilization 

Rules. Thus, if an election is made under:

- ERISA section 303(h)(2)(D)(ii) to use the full yield curve instead of the three segment rates for purposes 

of determining the minimum required contribution, that same yield curve is used to determine the 

Alternative Premium Funding Target; or

- ERISA section 303(h)(2)(E) to use one of the four months preceding the valuation date as the “applicable 

month,” instead of the month containing the valuation date, for determining which month’s rates to 

use, that same month’s rates, determined without regard to the Interest Rate Stabilization Rules, are 

used to determine the Alternative Premium Funding Target.

Until an election is officially revoked, it remains in place. An election to use the Alternative Premium Funding 

Target cannot be revoked for five calendar years. Similarly, once an election is revoked, the plan cannot make 

another election to use the Alternative Premium Funding Target for five full years. The following example 

illustrates the rules on making and revoking an election to use the Alternative Premium Funding Target.

12 Note that this will not be the case if the plan is not subject to the Pension Protection Act of 2006 (PPA) for funding purposes, or if an 

election is made under PPA section 402, to use an 8.25% discount rate to determine the funding target for funding purposes. See 

“Plans Subject to Special Funding Rules” later in this section.
How to Determine Unfunded Vested Benefits

Page 18

Example – Plan A first makes an election to use the Alternative Premium Funding Target for a plan year that 

begins on April 1, 2024. In this case, the Alternative Premium Funding Target must be used to determine UVBs

for all plan years beginning before April 1, 2028. The plan may revoke the election first effective for any plan 

year beginning on or after April 1, 2028, but unless the election is revoked, it will remain in place.

This is the case even if the plan year subsequently changes. For example, if the plan year is changed to the 

calendar year first effective January 1, 2028, the Alternative Premium Funding Target must be used for the Short 

Plan Year April 1, 2027 – December 31, 2027 and for the January 1, 2028 – December 31, 2028 plan year. The 

first plan year for which the Plan Administrator may revoke the election is the 2029 plan year.

The election (or revocation) must be made by the premium filing due date. An election to use (or revoke) the 

Alternative Premium Funding Target is made as part of the Comprehensive Premium Filing. If an election (or 

revocation) is not made as part of the Comprehensive Premium Filing, it may be made as part of an amended 

filing only if the amended filing is made on or before the due date.

Vested Benefits

Only vested benefits are taken into account when determining the Premium Funding Target. For this purpose, a 

benefit does not fail to be considered vested solely because it is not protected under Code section 411(d)(6) and 

thus may be eliminated or reduced by the adoption of a plan amendment or by the occurrence of a condition or 

event. Such a benefit is vested for premium purposes (if the other requirements for vesting have been met) so 

long as the benefit has not actually been eliminated or reduced. In addition, certain benefits payable upon a 

Participant’s death do not fail to be considered vested solely because the Participant is still living. The benefits to 

which this rule applies are a qualified pre-retirement survivor annuity (QPSA), a post-retirement survivor annuity 

such as the annuity paid after a Participant’s death under a joint-and-survivor or certain-and-continuous option, 

and a benefit that returns a Participant’s accumulated mandatory employee contributions. The following 

examples illustrate these concepts:

 Example 1 – Under Plan A, if a Participant retires at or after age 55 but before age 62, the Participant receives 

a temporary supplement from retirement until age 62. The supplement is not a qualified social security 

supplement (QSUPP) as defined in Treasury Reg. § 1.401(a)(4)-12 and is not protected under Code section 

411(d)(6). The temporary supplement is considered vested, and its value is included in the Premium Funding 

Target, for each Participant who, on the UVB Valuation Date, is at least 55 but less than 62, and thus eligible 

for the supplement. The calculation is unaffected by the fact that the plan could be amended to remove the 

supplement after the UVB Valuation Date.

 Example 2 – Plan B provides a QPSA upon the death of a Participant who has five years of service, at no 

charge to the Participant. The QPSA is considered vested, and its value is included in the Premium Funding 

Target, for each Participant who, on the UVB Valuation Date, has five years of service and is thus eligible for 

the QPSA. The calculation is unaffected by the fact that the Participant is alive on that date.

A Participant’s pre-retirement lump-sum death benefit (other than a benefit that returns accumulated 

mandatory employee contributions or a QPSA paid as a lump sum) is not vested if the Participant is living. 

Similarly, a disability benefit is not vested if the Participant is not disabled.
How to Determine Unfunded Vested Benefits

Page 19

Estimated Premium Funding Target

If the Premium Funding Target is not known by the due date, an estimated Variable-rate Premium may be paid 

on the due date. Doing so triggers a requirement to submit an amended filing at a later date to reconcile the 

actual Variable rate Premium with the estimate. In the event the actual Variable-rate Premium is greater than 

the estimate, penalties for late payment will be waived if the estimate meets certain criteria and the 

reconciliation filing is made by the end of the sixth calendar month that begins on or after the premium filing 

due date (generally April 30th after year end for calendar year plans). For additional information, see 

“Automatic Penalty Waiver for Certain Late Variable-rate Premiums” in the “Late Payment Charges” section.

Fair Market Value of Plan Assets

The asset measure underlying the UVB calculation is determined the same way assets are determined under 

ERISA section 303 except without regard to any averaging method. For premium purposes, the market value of 

assets is measured on the UVB Valuation Date and adjusted to account for contribution receipts using the same 

methodology as is used for funding purposes.

Adjustments for prior year contributions

If contributions for the plan year prior to the Premium Payment Year (or, in the case of a plan using the 

Lookback Rule, the plan year preceding the Lookback Year) are made after the UVB Valuation Date, the market 

value is increased to reflect the value of such contributions discounted to the UVB Valuation Date. The discount 

rate for this purpose is the ERISA section 303(h)(2)(A) effective interest rate for the plan year for which the 

contributions were made (as reported in item 5 of Schedule SB). For example, consider a calendar year plan with 

a January 1 UVB Valuation Date:

Contributions made in 2024 for the 2023 plan year are included in the January 1, 2024 asset value. Such 

contributions are discounted from the date made to January 1, 2024 using the 2023 effective interest rate. Such

contributions are included only to the extent made by the date of the premium filing.

Adjustments for current year contributions 

If contributions for the Premium Payment Year (or, in the case of a plan using the Lookback Rule, the Lookback 

Year), are made before the UVB Valuation Date, the market value is decreased to exclude the adjusted value of 

these current year contributions. For this adjustment, such contributions are increased to the UVB Valuation 

Date using the ERISA section 303(h)(2)(A) effective interest rate for the plan year for which they were made. This 

can happen only if the UVB Valuation Date is after the beginning of the plan year. For example, consider a 

calendar year Small Plan with a July 1 UVB Valuation Date:

Contributions made in April 2024 for the 2024 plan year are not included in the July 1, 2024 asset value. Such 

contributions are increased from the date made to July 1, 2024, using the 2024 effective interest rate. The July 1, 

2024 market value of assets are decreased by the adjusted value of contributions made in April 2024.

Comparison to asset value reported on Schedule SB

In the case of:

 a Small Plan using the Lookback Rule, the asset value reported is generally the same as the market value of 

assets required to be reported in the Schedule SB for the Lookback Year (item 2a). 

 any other plan, the asset value reported here is generally the same as the market value of assets required to 

be reported in the Schedule SB for the Premium Payment Year (item 2a).
How to Determine Unfunded Vested Benefits

Page 20

The amounts would differ only if a premium filing is made before the premium due date and prior year 

contributions are made after the premium filing is made (and thus not included in assets).

Summary

The following table summarizes the various dates and assumptions that are used to determine Variable-rate 

Premiums for 2024. Although Participant Count Date is not used to determine the Variable-rate Premium, it is 

included in the table so that all of the variables affecting premium calculations are contained in one summary. 

Please review the column that relates to your plan. 

Summary11F12F

13

If Lookback Rule Applies If Lookback Rule Does Not Apply

Standard Premium 

Funding Target

Alternative Premium Funding 

Target

Standard Premium 

Funding Target

Alternative Premium 

Funding Target

Participant 

Count Date 

Last day of 

2023 plan year

Last day of

2023 plan year

Last day of 

2023 plan year

Last day of 

2023 plan year

UVB Valuation 

Date

Funding valuation

date for 2023

Funding valuation

date for 2023

Funding valuation

date for 2024

Funding valuation

date for 2024

Benefits 

reflected in 

Premium 

Funding Target

Vested portion of

benefits included in

2023 funding target

Vested portion of

benefits included in

2023 funding target

Vested portion of

benefits included in

2024 funding target

Vested portion of

benefits included in

2024 funding target

Assumptions 

• Discount 

rates 

Spot segment rates for 

month before 2023 plan 

year begins 

Whatever would have been

used for funding purposes for 

2023 if Interest Rate

Stabilization Rules had not 

applied12F13F

14

Spot segment rates for 

month before 2024 plan 

year begins 

Whatever would be used 

for funding purposes for 

2024 if Interest Rate

Stabilization Rules did not 

apply13

• All other 

assumptions

Whatever was used

for funding purposes

for 2023

Whatever was used

for funding purposes

for 2023

Whatever is used

for funding purposes

for 2024

Whatever is used 

for funding purposes

for 2024

At-risk status Whatever status was

in effect for funding 

purposes for 2023

Whatever status was

in effect for funding

purposes for 2023

Whatever status is

in effect for funding 

purposes for 2024

Whatever status is

in effect for funding 

purposes for 2024

13 Table entries assume plan is not a New or Newly Covered Small Plan and that none of special Participant Count Date rules apply. The terms 

“funding” or “for funding purposes” in this table mean amounts determined under ERISA Section 303. References to 2023 or 2024 relate to 

the plan year beginning in such year. 14 This is not the case for plans that are not subject to the Pension Protection Act of 2006 (PPA) for funding purposes or frozen airline plans that 

made an election under section 402 of PPA. See “Plans Subject to Special Funding Rules” on next page.
How to Determine Unfunded Vested Benefits

Page 21

Summary (continued)

If Lookback Rule Applies If Lookback Rule Does Not Apply

Standard Premium 

Funding Target

Alternative Premium 

Funding Target

Standard Premium 

Funding Target

Alternative Premium 

Funding Target

At-risk load 

• 4% of 

liability 

portion of 

load

If the plan was at-risk for 

2023 for funding 

purposes, 4% of what

the Standard Premium 

Funding Target would be

if the plan wasn’t at-risk.

Otherwise, N/A.

If the plan was at-risk for

2023 for funding

purposes, 4% of what

the Alternative Premium 

Funding Target would be

if the plan wasn’t at-risk.

Otherwise, N/A.

If the plan is at-risk for 

2024 for funding

purposes, 4% of what

the Standard Premium

Funding Target would be

if the plan wasn’t at-risk.

Otherwise, N/A.

If the plan is at-risk for

2024 for funding

purposes, 4% of what

the Alternative Premium 

Funding Target would be

if the plan wasn’t at-risk.

Otherwise, N/A.

• Perparticipant 

portion of 

load

The same amount

included in the liability

for funding purposes

for 2023

The same amount

included in the liability

for funding purposes

for 2023

The same amount

included in the liability

for funding purposes

for 2024

The same amount

included in the liability

for funding purposes

for 2024

Plans Subject to Special Funding Rules 

Plans covered by the special funding rules listed below must determine UVBs in the same manner (and using the 

same discount rate basis) as all other plans. This includes:

 Section 402(b) of the Pension Protection Act of 2006, Public Law 109-280, dealing with certain frozen plans of 

commercial passenger airlines and airline caterers.

 Section 115 the SECURE Act, enacted on December 20, 2019, as Division O of Public Law 116-94, dealing with 

plans sponsored by certain community newspapers or members of such sponsors’ controlled group.
Premium Proration

Page 22

General

In certain situations, plans with Short Plan Years or Short Coverage years qualify to pay a prorated premium. For 

example, if a plan with a nine-month plan year qualifies for premium proration, only 75% (i.e., 9/12) of the unprorated premium is due. In addition, in some cases, premiums are prorated if the plan is not covered by PBGC 

for the entire plan year.

The situations in which premium proration applies (or does not apply) are described below.

Short Coverage Years

Premiums are prorated for Newly Covered Plans if the first day of coverage begins more than a month after the 

plan year begins. For example, if a calendar year plan becomes covered by PBGC in March of 2024, the premium 

is prorated (i.e., 10/12 of the un-prorated premium would be owed).

Premiums are not prorated to reflect a period of non-coverage that occurs during the plan year. For example, if 

a calendar year plan that’s covered on January 1, 2024 ceases to be covered on July 15, 2024, the full 2024

premium is owed.

Short Plan Years – in general

Premiums are prorated if the Short Plan Year: 

 Is the first year of a New Plan;

 Is the result of:

- an amendment that changes the plan year,13F14F

15

- the appointment of a trustee for a Single-employer Plan under ERISA section 4042, or

- plan assets being distributed pursuant to standard termination, unless the plan engaged in Spinoff that 

was not De Minimis during that same Short Plan Year. 

Premiums are not prorated if a Short Plan Year is the result of:

 A Merger or Consolidation with another plan, or

 Plan assets being distributed pursuant to a standard termination in the same Premium Payment Year the plan 

engaged in a Spinoff that was not De Minimis.

Reminder – plans that cease to exist mid-year because of a standard termination might be subject to an 

accelerated due date as explained in “When to File” section.

Short Plan Years that end after filing due date

If proration applies, you may pay a prorated premium even if the Short Plan Year has not ended by the time the 

premium is due. For example, consider a Single-employer plan with a calendar year plan year that expects to 

distribute plan assets pursuant to a standard termination on November 15, 2024. When preparing the 2024

premium filing (due October 15, 2024), you may report an anticipated distribution date of November 15, 2024

(see item 13 in the “Description of Data Elements” section) and prorate the premium.

15 An amendment is not considered to change the plan year if the plan merges into or consolidates with another plan or otherwise ceases 

its independent existence either during the Short Plan Year or at the beginning of the full plan year following the Short Plan Year.
Premium Proration

Page 23

However, if you take this approach and the plan year turns out to be longer than you anticipated (i.e., longer 

than what you report in the filing), you will have to make up any premium underpayment, which will be subject 

to late payment charges. This happens fairly regularly with respect to plans that are expecting to distribute plan 

assets pursuant to a standard plan termination near the end of the year because it often takes longer than 

expected to complete the distribution.

Recommended approach 

To avoid the possibility of late payment charges arising if the final distribution takes longer than expected, if you 

are anticipating a short final plan year as the result of distribution of plan assets pursuant to a standard plan 

termination, but the distribution hasn’t been completed by the premium due date, you may file without regard 

to the anticipated Short Plan Year. With this approach, you would:

 Report that the premium filing is for the full plan year (i.e., report the “plan year end” date as if the plan 

year is not a Short Plan Year.

 Pay the entire premium, without proration and without regard to the Variable-rate Premium exemption for 

plans distributing assets during the plan year (See instructions for line 7c in the “Description of Data 

Elements” section). 

 Not report that the premium filing is the final filing for the plan (See line 13 on the illustrative form in the 

“Data to be Submitted” section.

With this approach, it will not be necessary to amend the premium filing if it turns out the distributions are 

completed before year end. After the Form 501 (Post-Distribution Certification) is processed, PBGC will 

automatically prorate the premium, apply the Variable-rate Premium exemption (if applicable) and close out the 

premium account. Any overpayment will be available for refund. The refund can be requested by email or via 

the "Submit Request" link from the My PAA Plan Details Page. 

For more information about submitting requests via My PAA, see PBGC’s My PAA online demo web page.

Which months count for purposes of prorating premiums

Plans that qualify to prorate their premium pay a premium for each full or partial month in the Short Plan Year 

or Short Coverage Year. For example, if the Short Plan Year begins on January 1 and ends on June 15th, the Short 

Plan Year is considered to be a six-month plan year (i.e., five full months and one 15 -day partial month). That 

means the premium owed is 6/12 of the un-prorated amount. When counting months for:

 A Multiemployer Plan that distributed all its assets pursuant to ERISA section 4041A, the plan’s short final 

year is treated as ending on the date the distribution is completed.

 A Single-employer Plan that distributed all its assets pursuant to a standard termination, the plan’s short 

final year is treated as ending the date on which the distribution of the plan’s assets in satisfaction of all 

Benefit Liabilities was completed.

 A Single-employer Plan for which a trustee was appointed under ERISA section 4042, the plan’s short final 

year is treated as ending on the date the trustee was appointed.

 A New Plan, the Short Plan Year is treated as beginning on the Participant Count Date (i.e., the plan effective 

date).

 A Newly Covered Plan, the Short Coverage Year is treated as beginning on the date the plan becomes 

covered under ERISA section 4021.
Premium Proration

Page 24

How to count months for purposes of prorating premiums

Generally, when counting months (full and partial), each month in the plan year is treated as beginning on the 

same day of each successive calendar month. For example, if the plan year begins on July 1, the first day of each 

successive calendar month is the beginning of a new plan month. Similarly, if the plan year begins on January 15, 

the second plan month begins on February 15, the third plan month on March 15, etc.

There are two exceptions to this general rule that relate to plan years beginning on the 30th or 31st of a calendar 

year month:

 Plan years beginning on the 30th – If the plan year begins on the 30th day of a calendar month that contains:

─ 30 days, successive plan months, are treated as beginning on the last day of such successive month, 

even if that successive month contains 31 days (see example 1 below).

─ 31 days, successive plan months are treated as beginning on the 30th day of such successive month, or in 

the case of February, the last day of the month (see example 2 below).

 Plan years beginning on the 31st – If the plan year begins on the 31st day of a calendar month, successive 

plan months are treated as beginning on the last day of such successive month (see example 3 below). 

These special rules are illustrated in the following examples.14F15F

16

Example 1 – Plan A qualifies for premium proration for its final plan year which begins on November 30th (the 

last day of November) and ends on March 6th. All subsequent months in the final plan year are treated as 

beginning on the last day of the calendar month. Accordingly, there are four (full or partial) months in the 

proration period: November 30 to December 30, December 31 to January 30, January 31 to February 27, and 

February 28 to March 6.

Example 2 – Plan B qualifies for premium proration for its final plan year which begins on December 30th and 

ends on March 12th. With the exception of February, all subsequent months in the final plan year are treated as 

beginning on the 30th day of the calendar month. February is treated as beginning on February 28th. Accordingly, 

there are three (full or partial) months in the proration period: December 30 to January 29, January 30 to 

February 27, and February 28 to March 12.

Example 3 – Plan C qualifies for premium proration for its final plan year which begins on January 31st and ends 

on April 26th. All subsequent months in the final plan year are treated as beginning on the last day of the 

calendar month. Accordingly, there are three (full or partial) months in the proration period: January 31 to 

February 27, February 28 to March 30, March 31 to April 26. 

16 In examples 2 and 3, if February of the final plan year falls in a leap year, references to February 27 change to February 28 and 

references to February 28 change to February 29.
Spinoffs, Mergers and Consolidations

Page 25

General

This section provides additional guidance for plans involved in a Spinoff, Merger, or Consolidation. Plans 

considering any of these transactions are encouraged to read this section carefully before finalizing the 

transaction because decisions that have little impact on funding requirements can have a significant 

impact on the amount of premium due and the due date. For example, with respect to a 

non-De Minimis Spinoff to a New Plan, the aggregate premium due for both plans will generally be less 

if the Spinoff occurs at the beginning of the plan year. Also, when combining two plans, aggregate 

premium amounts will differ depending on, for example, whether Plan A is merged into Plan B, Plan B is 

merged into Plan A, or the two plans are consolidated into a New Plan C.

Note that as the result of one of these transactions, a plan could become a Small Plan for the first time 

or cease to be a Small Plan. Filers are cautioned to review the Lookback Rule provisions in either of 

these situations (See “How to Determine UVBs” section).

Information about Spinoffs, Mergers and Consolidations are reported by all PBGC-covered plans 

involved in the transaction as part of the Comprehensive Premium Filing in items that request 

information about “Transfers from other plans” and “Transfers to other plans”. See “Description of Data 

Elements” section, items 14 and 15.

Spinoffs

A “Spinoff” is a transaction in which a plan (the Transferor Plan) transfers a portion of its assets and/or 

liabilities to another plan (the Transferee Plan). The Transferee Plan may be a New Plan, created by the 

Spinoff, or it may be a pre-existing plan.

If the Transferee Plan is a New Plan, all of the special rules applicable to New Plans apply. For example, 

for the New Plan’s first plan year:

 Depending on when the transaction occurs and the plan’s UVB Valuation Date, the due date might 

be later than the Normal Due Date (see “When to File” section).

 The applicable Participant Count Date for purposes of determining the Flat-rate Premium is the first 

day of the Premium Payment Year (see “How to Count Participants section”).

 The Standard Premium Funding Target is used to determine the Variable-rate Premium unless the 

plan makes a timely election to use the Alternative Premium Funding Target. This is the case even if 

the Transferor Plan had an election to use the Alternative Premium Funding Target in effect or 

revoked such an election fewer than five years prior to the Spinoff (see “How to Determine 

Unfunded Vested Benefits” section”).

 If the plan is a Small Plan, the Lookback Rule does not apply because there is no prior plan year to 

look back to. The Lookback Rule will automatically apply for the plan’s second year of existence, 

unless the plan opts out of using that rule (see “How to Determine Unfunded Vested Benefits” 

section).

 If the Spinoff is De Minimis (i.e., if the plan is not a Continuation Plan) and the plan is a Small Plan, 

the plan is exempt from the Variable-rate Premium.
Spinoffs, Mergers and Consolidations

Page 26

Mergers

A “Merger” is a transaction in which a plan transfers all of its assets and liabilities to an existing plan 

and, as a result, ceases to exist. In essence, the Transferor Plan becomes part of the Transferee Plan.

If, as the result of a Merger, a plan ceases to exist, in addition to reporting information about the 

transaction, the fact that the filing is the last filing for the plan must also be reported.15F16F

17 (See 

“Description of Data Elements” section, item 13). 

Consolidations

A “Consolidation” is a transaction in which two or more plans transfer all of their assets and liabilities to 

a New Plan and, as a result, cease to exist (because the Transferor Plans become part of the new 

Transferee Plan). It differs from a Merger because in a Merger, the Transferee Plan existed before the 

transaction. In a Consolidation, the Transferee Plan is a New Plan that is created in the Consolidation. 

Thus, the plan that exists after a Consolidation follows the premium filing rules for New Plan.

If, as the result of a Consolidation, a plan ceases to exist, in addition to reporting information about the 

transaction, you must also report that the filing is the last filing for the plan. (See “Description of Data 

Elements” section, item 13).16 

Examples

The following examples illustrate the effect of these transactions on premiums. For purposes of these 

examples, assume all plans have been covered by PBGC since inception and that none of the affected 

plans are Small Plans (which means they all have beginning of year valuation dates and none of them 

use the Lookback rule for determining UVBs).

Example 1 (Beginning of Plan Year Spinoff to a New Plan) — Plan B is created at the beginning of 2024 as 

the result of a non-De Minimis Spinoff from Plan A (a plan with a calendar year plan year). Plan B will 

also have a calendar year plan year. Plan A made an election to use the Alternative Premium Funding 

Target in 2010; such election is still in effect.

For 2024, premiums for these plans are determined as follows:

 Due date — Premiums for both plans are due October 15, 2024.

 Participant Count Date:

- Plan A: Because the Spinoff occurred at the beginning of Plan A’s plan year, Plan A’s 2024

Flat-rate Premium is based on the Participant count on the first day of the plan year (January 1, 

2024) instead of the last day of the prior year (December 31, 2023). As a result, Plan A does not 

include the spun off Participants in its Participant count. See special rule re: beginning of year 

non-De Minimis Spinoffs in “How to Count Participants” section.

- Plan B: Because Plan B is a New Plan, its Participant Count Date is also the first day of the plan 

year (January 1, 2024).

17 If a plan ceases to exist because of a Merger or Consolidation and the transaction occurs after the premium filing is 

submitted, please contact PBGC via email at premiums@pbgc.gov, so we can update our records. Absent this notification, 

PBGC will likely contact the plan (that no longer exists) to inquire about why the subsequent year’s filing is not submitted.
Spinoffs, Mergers and Consolidations

Page 27

Note – if the Spinoff had been De Minimis, the special Participant Count Date rule would not apply 

(i.e., Plan A’s Participant Count Date would have been December 31, 2023). Because Plan B’s 

Participant Count Date is January 1, 2024, that means both plans would have owed Flat-rate 

Premiums on behalf of the Participants that were spun off from Plan A to Plan B.

 UVB Measurement Date — Both plans measure UVBs as of January 1, 2024.

 Premium Funding Target:

- Plan A: The Alternative Premium Funding Target is used unless the election is revoked as part of 

the 2024 Comprehensive Premium Filing.

- Plan B: As a New Plan, the Variable-rate Premium must be determined using the Standard 

Premium Funding Target unless the Plan makes a timely election to use the Alternative Premium 

Funding Target (as part of its 2024 filing).

 Proration — Neither plan qualifies to prorate its 2024 premium.

 Reporting on Comprehensive Premium Filing (item 14):

- Plan A checks the “Transferor Plan” box (item 14a), the “Spinoff to/from another plan” box for 

the type of transfer question (item 14c), and the “No” box for the De Minimis question (item 

14e).

- Plan B checks the “Transferee Plan” box (item 14a), the “Spinoff to/from another plan” box for 

the type of transfer question (item 14c). The De Minimis question (item 14e) is left blank

because Plan B is a New Plan and New Plans are not required to answer that question.

Example 2 (Mid-year Spinoff to a New Plan) — Plan B is created on July 1, 2024 as the result of a Spinoff 

from Plan A. Plan B’s first plan year will be a Short Plan Year (i.e., July 1, 2024 – December 31, 2024).

Plan A made an election in 2010 to use the Alternative Premium Funding Target that is still in effect. For 

2024, premiums are determined as follows:

 The Spinoff has no effect on Plan A’s 2024 premium obligation. That means:

- Due Date: October 15, 2024.

- Flat-rate Premium: Based on the Participant count as of December 31, 2023. There is no 

adjustment for Participants who are spun off later in the year.

- Variable-rate Premium: UVBs are:

o Measured as of January 1, 2024. There is no adjustment for the assets and/or liabilities that 

are spun off later in the year.

o Determined using the Alternative Premium Funding Target unless the Plan makes a timely 

election to revoke the prior election (as part of its 2024 filing).

 Plan B is subject to special rules because it is a New Plan. For example:

- Due date: April 15, 2025 (i.e., the 15th day of the 10th full calendar month after July 1, 2024).

- Flat-rate Premium: Based on the Participant count on July 1, 2024. The fact that some of these 

Participants may have been included in the Participant count for Plan A’s 2024 Flat-rate 

Premium has no bearing on Plan B’s Flat-rate Premium.
Spinoffs, Mergers and Consolidations

Page 28

- Variable-rate Premium: UVBs are:

o Measured on the same date used to determine funding requirements for Plan B’s first 

(short) plan year.

o Determined using the Standard Premium Funding Target unless the Plan makes a timely 

election to use the Alternative Premium Funding Target (as part of its 2024 filing).

- Proration: Because the first plan year is a Short Plan Year and the plan was created as the result 

of a Spinoff, the 2024 premium is prorated. There are six months in the Short Plan Year (July 1, 

2024 – December 31, 2024), so the plan owes 50% (i.e., 6/12) of the otherwise determined 

premium. Note that for proration purposes, a partial month is treated as a full month. So, had

the Spinoff had occurred on July 25th instead of July 1st, the result would be the same.

 Reporting on Comprehensive Premium Filing:

- Plan A checks the “Transferor Plan” box (item 14a), the “Spinoff to/from another plan” box for 

the type of transfer question (item 14c). The De Minimis question (item 14e) is left blank 

because the transfer did not occur at the beginning of Plan A’s plan year.

- Plan B checks the “Transferee Plan” box (item 14a), the “Spinoff to/from another plan” box for 

the type of transfer question (item 14c). The De Minimis question (item 14e) is left blank

because Plan B is a New Plan

Example 3 (Mid-year Spinoff to a pre-existing plan) — Plans A and B are both calendar year plans. Both 

plans made an election in 2018 to use the Alternative Premium Funding Target that is still in effect. On 

July 1, 2024, Plan A spun off assets and liabilities for Participants in Location XYZ to Plan B.

 In this scenario, the Spinoff has no effect on the amount of premium owed or the due date for the 

2024 plan year of either plan.

 Reporting on Comprehensive Premium Filing:

- Plan A checks the “Transferor Plan” box (item 14a), the “Spinoff to/from another plan” box for 

the type of transfer question (item 14c). The De Minimis question (item 14e) is left blank 

because the transfer did not occur at the beginning of Plan A’s plan year.

- Plan B checks the “Transferee Plan” box (item 14a), the “Spinoff to/from another plan” box for 

the type of transfer question (item 14c). The De Minimis question (item 14e) is left blank 

because the transfer did not occur at the beginning of Plan B’s plan year and in such cases, that 

question is not required to be answered.

Example 4 (Beginning of year Merger) — Plans A and B are both calendar year plans. On January 1, 2024, 

Plan B merges into Plan A. The Merger is not De Minimis.

The Merger’s impact on 2024 premiums is as follows:

 Because the Merger (1) was not De Minimis and (2) occurred at the beginning of Plan A’s plan year, 

Plan A’s 2024 Flat-rate Premium is based on the Participant count on the first day of the plan year 

(January 1, 2024) instead of the last day of the prior year (December 31, 2023). (See special rule re: 

beginning of year Mergers in “How to Count Participants” section).
Spinoffs, Mergers and Consolidations

Page 29

 Plan B is not required to submit a 2024 Comprehensive Premium Filing because the plan ceased to 

exist on what would have been the first day of Plan B’s 2024 plan year. In other words, the Merger is 

deemed to be effective before the 2024 plan year begins.

 Reporting on Comprehensive Premium Filing: Plan A checks the “Transferee Plan” box (item 14a), 

the “Merger” box for the type of transfer question (item 14c), and the “No” box for the De Minimis 

question (item 14e).

Because the Merger did not occur until after the due date for Plan B’s 2023 Comprehensive Premium 

Filing, PBGC expects that Plan B would not have reported that 2023 would be its “Final Filing” as part of 

its 2023 filing. As long as Plan A properly reports the Merger in its 2024 filing, it is not necessary for Plan 

B to amend its 2023 filing to indicate that that is the final filing. 

Note – if the Merger had been De Minimis, the special Participant Count Date rule would not apply (i.e., 

Plan A’s Participant Count Date would have been December 31, 2023). Exception – if the plan reports 

that the Merger is De Minimis, but the surviving plan was the smaller of the two plans, the special 

Participant Count Date rule would apply. See instructions for item 14e for a description of which plan is 

considerers the “smaller” of the two plans.

Example 5 (Mid-year Merger) — Plan A is a calendar year plan. Plan B has a plan year that begins on 

March 1. On February 1, 2024, Plan B merges into Plan A.

The Merger’s impact on 2024 premiums is as follows:

 The Merger has no effect on Plan A’s premium obligation. Among other things, that means the 

Flat-rate Premium is based on the Participant count as of December 31, 2023 (i.e., the Plan B 

Participants that merged into Plan A on February 1, 2024 are not included). 

 Plan B is not required to submit a 2024 Comprehensive Premium Filing because the plan ceased to 

exist before its 2024 plan year would have begun (i.e., before March 1, 2024).

 Plan A checks the “Transferee Plan” box (item 14a) and the “Merger” box for the type of transfer 

question (item 14c). The De Minimis question (item 14e) is left blank because the transfer did not 

occur at the beginning of Plan A’s plan year.

 Because the Merger did not occur until after the due date for Plan B’s 2023 Comprehensive 

Premium Filing, PBGC expects that Plan B would not have reported that 2023 would be its “Final 

Filing” as part of its 2023 filing. As long as Plan A properly reports the Merger in its 2024 filing, it is 

not necessary to amend Plan B’s 2023 filing to indicate that it’s the final filing.

Example 6 (Mid-year Merger) — Plan A is a calendar year plan. Plan B has a plan year that begins on 

October 1. Plan B merges into Plan A on December 1, 2024. The Merger’s impact on premiums is as 

follows:

 Plan A: The Merger has no effect on the amount of Plan A’s 2024 premium. Because the Merger 

occurs after the due date for Plan A’s 2024 Comprehensive Premium Filing, Plan A will not report the 

Merger in the “Transfers between plans” item until the 2025 filing.
Spinoffs, Mergers and Consolidations

Page 30

 Plan B: Although Plan B’s 2024 plan year is a Short Plan Year (October 1, 2024 – November 30, 

2024), Plan B’s 2024 premium is not prorated because the Short Plan Year was created as the result 

of a mid-year Merger. In its 2024 Comprehensive Premium Filing:

‒ Plan B indicates this is a “Final Filing” due to Merger in item 13.

‒ Plan B checks the “Transferor Plan” box (item 14a), the “Merger” box for the type of transfer

question (item 14c). The De Minimis question (item 14e) is left blank because the transfer did not 

occur at the beginning of Plan B’s plan year.

Example 7 (Beginning of Plan Year Spinoff to an Existing Plan) — Plans A and B are both calendar year 

plans. On January 1, 2024, Plan A spun off assets and liabilities for Participants in Location XYZ to Plan B.

For 2024, premiums for these plans are determined as follows:

 Due date — Premiums for both plans are due October 15, 2024.

 Participant Count Date:

- Plan A: Because the Spinoff occurred at the beginning of Plan A’s plan year, Plan A’s 2024

Flat-rate Premium is based on the Participant count on the first day of the plan year (January 1, 

2024) instead of the last day of the prior year (December 31, 2023). As a result, Plan A does not 

include the spun off Participants in its Participant count. See special rule re: beginning of year 

non-De Minimis Spinoffs in “How to Count Participants” section.

- Plan B: Because the transfer occurred at the beginning of Plan B’s plan year and was not 

considered a De Minimis Spinoff (with respect to Plan A), Plan’s B’s Participant Count Date is 

also the first day of the plan year (January 1, 2024). As a result, Plan B, the Transferee Plan, 

includes the spun off Participants in its Participant count.

Note – if the Spinoff had been De Minimis, the special Participant Count Date rule would not apply 

for either plan (i.e., The Participant Count Date for both plans would have been December 31, 

2023).

 UVB Measurement Date — Both plans measure UVBs as of January 1, 2024.

 Proration — Neither plan qualifies to prorate its 2024 premium.

 Reporting on Comprehensive Premium Filing:

- Plan A checks the “Transferor Plan” box (item 14a), the “Spinoff to/from another plan” box for 

the type of transfer question (item 14c) and checks “No” for the De Minimis question (item 14e).

- Plan B checks the “Transferee Plan” box (item 14a), the “Spinoff to/from another plan” box for 

the type of transfer question (item 14c) and checks “No” for the De Minimis question (item 14e).
Data to be Submitted

Page 31

The following image provides a comprehensive list, in a traditional “form” format, of the data that must be 

submitted electronically via My PAA. This is for illustrative purposes only.

Amended filing 2024 PBGC Comprehensive Premium Filing Disaster Relief 

Part I – General Plan Information

1 Plan sponsor information

a Name ____________________________________________________________________________________________

b Six-digit business code _ _ _ _ _ _ _ c First six digits of CUSIP number _ _ _ _ _ _ 

2 Plan administrator information 

a Name ___________________________________________________________________________________________________________

b Address line 1 ____________________________________________________________________________________________________

c Address line 2 ____________________________________________________________________________________________________

d City ____________________________ e State ________ f Zip _______________ g Country (if not U.S.) _____________

h Contact person 

(1) Name (for “attention” line of mailings) __________________________________________________________________ 

(2) e-mail address ______________________________ (3) Phone number: _ _ _ -_ _ _ - _ _ _ _ ext _ _ _ _ _ 

i Alternative phone number (for “Plan Paying Premiums” list on pbgc.gov): _ _ _ -_ _ _ - _ _ _ _ ext _ _ _ _ _ 

3 Additional plan contact (optional)

(1) Name _________________________________________________________________________________ 

(2) e-mail address ___________________________________________________ (3) Phone number _ _ _ -_ _ _ - _ _ _ _ ext _ _ _ _ _ 

4 Plan information

a Plan name _____________________________________________________________________________________________________

b Premium payment year information: 

(1) This filing is for the premium payment year commencing _ _ /_ _ / _ _ _ _ and ending _ _ /_ _ / _ _ _ _.

(2) For the premium payment year, is the plan a “small plan” (see definitions section of instructions)? Yes No 

(3) If the plan year commencement date has changed since the most recent PBGC filing as a result of a plan amendment changing the plan year, enter the date 

the plan year change was adopted _ _/_ _/_ _ _ _.

(4) Check box if plan qualifies to pay a prorated premium for this premium payment year.

c Employer Identification Number and Plan Number information: 

(1) EIN and PN: EIN _ _ _ _ _ _ _ _ _ PN _ _ _ 

(2) If the EIN and PN are not both the same as on the most recent premium filing, enter EIN and PN from most recent premium filing: 

EIN _ _ _ _ _ _ _ _ _ PN _ _ _. Otherwise, skip to item 4c(3). 

(3) If the EIN and PN are not both the same as on the 2023 Form 5500, enter EIN and PN from 2023 Form 5500 and provide explanation: Otherwise, skip to 

item 4d. EIN _ _ _ _ _ _ _ _ _ PN _ _ _. Explanation _____________________________________________________________________________________ 

d Plan effective date _ _ /_ _ / _ _ _ _ 

e Plan type: Multiemployer Single-employer other than CSECs (including multiple-employer plans) CSEC Plan

f Check box if plan is a new or newly covered plan and provide the following information: 

(1) Adoption date _ _ /_ _ / _ _ _ _ (2) Date coverage began on _ _ /_ _ / _ _ _ _. 

(3) Is the plan a “continuation plan” (see definitions section of instructions)? Yes No
Data to be Submitted

Page 32

Part III – Variable-rate Premium Information

Multiemployer plans — Skip to Part IV

Complete item 6 only if the plan is electing, or revoking an election, to use the Alternative Premium Funding Target instead of the Standard Premium Funding Target; 

otherwise skip to item 7. CSEC plans may not make this election.

6 Alternative Premium Funding Target Election or Revocation

a Election - Check box to elect to use the Alternative Premium Funding Target instead of the Standard Premium Funding Target. The election will be effective —

and the plan will be required to use the Alternative Premium Funding Target — beginning with this premium payment year and for all subsequent plan years 

unless and until the election is subsequently revoked.

b Revocation - Check box to revoke a prior election to use the Alternative Premium Funding Target. The revocation will be effective — and the plan will be 

required to use the Standard Premium Funding Target — beginning with this premium payment year and for all subsequent plan years unless and until a new 

election is subsequently made.

Note — Elections or Revocations must remain in place for at least five years.

7 Variable-rate Premium (VRP)

a VRP exemptions – If an exemption applies, check applicable box and skip to item 8. 

 New or newly covered small plan other than a continuation plan No vested participants 

 Standard termination with a final distribution during the premium payment year 412(e)(3) plan 

 Standard termination with a proposed termination date in a prior year (proposed termination date: _ _ /_ _ /_ _ _ _)

b VRP small employer cap qualification – Check box if this plan qualifies for the small employer cap applicable to certain plans of small employers (those with 25 

or fewer employees). If box is checked, items 7c through 7g may, but need not, be omitted. 

c Assumptions and methods used to determine premium funding target 

(1) Premium funding target method: Standard Alternative NA, CSEC 

(2) Discount rate(s): 1st segment ____% 2nd segment ____% 3rd segment ____% N/A, full yield curve used CSEC plan rate _____%

(3) UVB valuation date: Month ___ Day ___ Year ____

d Premium funding target as of UVB valuation date – Check box if the reported premium funding target information is an estimate. 

(1) Attributable to active participants _____________

(2) Attributable to terminated vested participants _____________

(3) Attributable to retirees and beneficiaries receiving payment _____________

(4) Total premium funding target (item 7d(1) + item 7d(2) + item 7d(3)) _____________

e Market value of assets as of UVB valuation date _____________

f Unfunded vested benefits (excess, if any, of item 7d(4) over item 7e, rounded up to the next $1,000) _____________

g Uncapped variable-rate premium (CSEC plans, item 7f x 0.009. Other plans, item 7f x .052) _____________

h Maximum VRP

(1) MAP-21 cap ($686 item 5b(2)) _____________

(2) Small employer cap, if applicable ($5 x item 5b(2) x item 5b(2)) – Omit this item if plan is not eligible for this cap _____________

(3) Maximum variable-rate premium — If the plan qualifies for the small employer cap, the lesser of item 7h(1) and 7h(2). Otherwise, 

item 7h(1). _____________

i Variable-rate premium — If the plan qualifies for the small employer cap and item 7g was omitted, item 7h(3). Otherwise, the lesser 

of item 7g and item 7h(3). _____________

Part II – Flat-Rate Premium Information

5 Flat-rate Premium 

a Participant count date: Month ___ Day ___ Year ____

b Flat-rate premium calculation

(1) Applicable rate (Single-employer plans other than CSECs - enter $101; Multiemployer plans - enter $37; CSEC plans- enter $19) ______________

(2) Participant count as of participant count date

Active: ___________ Terminated vested: _____________ Retirees and beneficiaries: _________ Total: ______________

(3) Flat-rate premium (item 5b(1) x item 5b(2)) ______________
Data to be Submitted

Page 33

Part IV – Total Premium Information

8 Premium proration (If the plan does not qualify for premium proration, skip to item 9)

a Number of months (complete and partial) in the short plan year or short coverage year ______________

b Total premium before reflecting proration (item 5b(3) + item 7i, if applicable) ______________

9 Total premium — If the plan does not qualify for premium proration, item 5b(3) + item 7i, if applicable. If the plan qualifies for premium 

proration, item 8b x item 8a ÷ 12. ______________

Part V – Payment Information

10 Premium credit 

a Payments made previously for this premium payment year (including credits used) ______________

b Outstanding credit from prior premium payment years ______________

c Total (item 10a + item 10b) ______________

11 Amount due (excess, if any, of item 9 over item 10c) ______________

12 Treatment of overpayment 

a Excess, if any, of item 10c over item 9 ______________

b Treatment of balance (select one): Credit towards next year’s premium Refund by check

 Refund by electronic funds transfer (ACH). If you select this option, complete item 12c.

c Information for ACH refund: Type of account Checking Savings Bank routing number _______________________

 Account number ___________________________

Part VI – Miscellaneous Information

13 Final filing – If this is the last filing for this plan, enter the date of event _ _ /_ _ / _ _ _ _ and check box that best describes why filing obligation is ceasing:

 Merger/Consolidation Trusteeship Distribution pursuant to termination Cessation of covered status (enter explanation)

_______________________________________________________________________________________________________________

_______________________________________________________________________________________________________________

14 Transfers between plans – If this plan transferred some, or all assets or liabilities to another plan (or vice versa) since the most recent comprehensive premium 

filing, provide the following information with respect to the plan to (or from) which assets or liabilities were transferred (if transfer involved a new or newly 

covered plan or if more than one transfer needs to be reported, see instructions). 

a Check box for (1) or (2), whichever is applicable box: (1) This plan is the transferor plan. (2) This plan is the transferee plan.

b Employer Identification numbers and plan numbers: Transferor Plan: EIN _ _ _ _ _ _ _ _ _ PN _ _ _ Transferee Plan EIN _ _ _ _ _ _ _ _ _ PN _ _ _

c Type of transfer: Merger Consolidation Spinoff to/from another plan Other d Date of transfer _ _ /_ _ / _ _ _ _

e Additional information for certain transactions. Complete this item only if the transfer occurred on the first day of the plan year and the plan is not a new plan.

(1) Was transfer de minimis? Yes No

(2) If plan is the transferee plan in a de minimis merger, was plan smaller than transferor plan (see instructions)? Yes No 
Data to be Submitted

Page 34

15 Participation freeze – If, as of the beginning of the premium payment year, this plan is closed to new entrants, enter the date the plan became closed to new 

entrants _ _/_ _/_ _ _ _. 

16 Accrual freeze – If, as of the beginning of the premium payment year, benefit accruals under this plan are partially or totally frozen, enter the date the freeze 

became effective_ _/_ _/_ _ _ _ and check box that best describes the nature of the freeze: 

For all participants, both pay and service are frozen For all participants, service is frozen, pay is not 

For some participants, both pay and service are frozen For some participants, service is frozen, pay is not

Other (enter explanation) ________________________________________________________________________________

17 Risk transfer activity – Do not complete this item if this is the last filing for this plan

a Lump Sum Windows: If the plan provided one or more lump sum windows during the prior premium payment year, report the number of participants eligible to 

elect a lump sum under all such windows and the number of participants who elected a lump sum:

(1) Participants not in pay status when lump sum was offered: Eligible to elect lump sum _______ Elected lump sum _______

(2) Participants in pay status when lump sum was offered: Eligible to elect lump sum _______ Elected lump sum _______

b Annuity purchases: If the plan purchased annuities for a group of participants during the prior premium payment year, report the number of participants for 

whom an annuity was purchased:

(1) Participants not in pay status when annuity was purchased: _______

(2) Participants in pay status when annuity was purchased: _______

18 Amended filing – Complete this item only if this is an amended filing

a If either the first or last day of the premium payment year reported in this amended filing (item 4b(1)) differs from what was reported in the filing that is being 

amended, provide the dates that were reported in the original filing:

Date premium payment year commenced _ _ /_ _ /_ _ _ _ Date premium payment year ended _ _ /_ _ /_ _ _ _.

b If the EIN and PN reported in this amended filing (item 4c(1)) are not both the same as what was reported in the filing that is being amended, enter the EIN and 

PN from the original filing: EIN _ _ _ _ _ _ _ _ _ PN _ _ _.

c If the reason for amending the filing is other than reconciling an estimated Variable-rate Premium and the total premium reported in this amended filing 

(item 9) is less than the amount reported in the filing that is being amended, provide an explanation of why an amended filing is necessary: 

_____________________________________________________________________________________________________________________________ 

_____________________________________________________________________________________________________________________________

19 Disaster relief – Complete this item only if this filing is subject to an extended due date per PBGC’s disaster relief announcement.

a Identifying number of applicable IRS Disaster Relief News Release (e.g., CA-2024-01): _ _ - _ _ _ _ - _ _ 

b Is the plan administrator’s address (i.e., address reported in item 2) in the disaster area covered by the applicable IRS News Release? Yes No

c Complete this item only if item 19b is “No”. Enter the information below as it relates to the person affected by the disaster.

(1) Name ________________________________________ (2) Role ________________________________________

(3) Address line 1 _____________________________________________________________________________________________________

(4) Address line 2 _____________________________________________________________________________________________________

(5) City_________________________ (6) State ___ (7) Zip___________________________
Data to be Submitted

Page 35

Part VII – Certifications

20 Certification of Plan Administrator – The plan administrator must sign and complete this item. 

I certify under penalty of perjury, to the best of my knowledge and belief, that all the information in the filing is true, correct and complete and has been determined 

in accordance with PBGC's premium regulations and instructions, except that if the filing reports an estimated premium funding target, the estimate is reasonable, 

takes into account the most current information available to the enrolled actuary, and has been determined in accordance with generally accepted actuarial 

principles and practices, and that if I received Variable-rate Premium information certified by an enrolled actuary for this filing, the Variable-rate premium 

information in the filing is the same as the Variable-rate Premium information certified by the enrolled actuary.

Name of person signing: First name _______________ Last name _____________________________

____________________________________________ _ _ _ -_ _ _ - _ _ _ _ ext _ _ _ _ _ _ 

E-mail address Telephone

___________________________________________ _ _ /_ _ /_ _ _ _

Signature Date

21 Certification of Enrolled Actuary – An enrolled actuary must sign and complete this item unless the plan is (1) a multiemployer plan, (2) exempt from the Variablerate Premium, or (3) eligible for the small employer cap, paying the maximum VRP and not reporting the uncapped VRP. 

I certify under penalty of perjury, to the best of my knowledge and belief, that the Variable-rate Premium information in the filing is true, correct and complete and 

has been determined in accordance with PBGC's premium regulations and instructions; except that if the premium funding target is estimated, the estimate is 

reasonable, takes into account the most current information available to me and has been determined in accordance with generally accepted actuarial principles 

and practices.

Name of person signing: First name _______________ Last name _____________________________

_____________________________________________ _ _ _ -_ _ _ - _ _ _ _ ext _ _ _ _ _ _ 

Firm Telephone

_____________________________________________ _ _ -_ _ _ _ _

E-mail address Enrollment number

____________________________________________ _ _ /_ _ /_ _ _ _

Signature Date
Description of Data Elements

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Overview

This section provides a description of each required data element presented in the same order as the “form” 

used to illustrate the data elements (see “Data to be Submitted” section). Item numbers are presented solely to 

facilitate understanding. The My PAA screens do not include item numbers. If you are using private-sector 

software, item numbers may or may not be included. We recommend you review these instructions with a copy 

of the “form” in front of you.

Note for plans with more than one plan year beginning in 2023 or 2024 - References in these instructions to the 

2023 plan year (and to filings for the 2023 plan year) should be considered to refer to your plan’s most recent 

complete plan year. For example, a plan that changes its plan year could have two plan years beginning in 

calendar 2024. When such a plan makes its premium filing(s) for its second 2024 plan year, the references in 

these instructions to the 2023 plan year (and to filings for the 2023 plan year) should be considered to refer to 

the plan’s first 2024 plan year (and to filings for the first 2024 plan year), because that is the plan’s most recent 

complete plan year. Similarly, if your plan had two plan years beginning in calendar 2023, the references in these 

instructions to the 2023 plan year (and to filings for the 2023 plan year) should be considered to refer to the 

plan’s second 2023 plan year, which is the plan’s most recent complete plan year.

Note about reporting dollar amounts - With the exception of total premium, premium credits, the amount due 

PBGC, and the amount of any overpayment, money amounts reported should be in dollars only (no cents). UVBs

are rounded up to the next $1,000.

Amended Filing 

Check this box only if this filing is an amendment to a previously submitted filing for the 2024 plan year. If this is 

an amended filing, be sure to complete item 18.

Note that a Variable-rate Premium reconciliation filing (in which you provide final Premium Funding Target 

information after having reported an estimated Premium Funding Target) is considered an amended filing. If you 

amend a comprehensive filing for a reason other than reconciling an estimated Variable-rate Premium and the 

amended filing shows a lower premium than the amount that was reported in the filing that is being amended, 

you must provide an explanation of the specific circumstances or events that caused the reduction. See the 

“Correcting Errors, Credit Balances and Reconciling Estimates” section for more information.

If you are amending a filing for a plan year that did not begin in 2024, the rules in this document do not apply.

Disaster Relief 

If your plan is eligible for disaster relief, check the box and be sure to complete item 19. For more information, 

see PBGC’s Disaster Relief web page.

Instructions for Part I – General Plan Information

1 Plan sponsor information

a Report the name of the Plan Sponsor. 
Description of Data Elements

Page 37

b Business Code – Report the six-digit business code that:

 In the case of a Single-employer Plan, best describes the primary nature of the plan sponsor’s 

business, and

 In the case of a Multiemployer Plan, best describes the predominant industry in which the active 

Participants are employed (e.g., 484120 - General Freight Trucking, Long-distance, 236110 -

Residential Building Construction).

A list of business codes can be found in the instructions to Form 5500 and on PBGC’s “Premium Filings” web 

page. Because codes for the Premium Payment Year may not be available at the time you submit this filing, 

you may report the relevant code for either the Premium Payment Year or the prior year.

Do not enter code 525100 (Insurance & Employee Benefit Funds) or 813930 (Labor Unions and Similar Labor 

Organizations) unless such code satisfies the above description of what the code represents.

c CUSIP number – If a CUSIP number has been assigned to publicly traded securities of the Plan Sponsor or 

any member of the Plan Sponsor’s controlled group, report the first six digits of the CUSIP number. 

Otherwise, leave this item blank. 

A CUSIP number is a nine-digit number assigned to the publicly traded securities of a Plan Sponsor (or 

member of the Plan Sponsor’s controlled group) under the securities numbering system of the Committee 

on Uniform Securities Identification Procedures. The first six digits of the CUSIP number identify the 

securities issuer, the next two digits identify the specific securities issue, and the last digit is a check digit.

2 Plan administrator information 

a-g Report the name and address of the Plan Administrator. Note that this is the address where we send 

official correspondence to the plan (e.g., an invoice for late payment charges). 

h Report the name, e-mail address, and phone number of the person we should contact if we have any 

questions concerning this filing. We will send official correspondence to the “attention of” this person at 

the address reported in 2(b)-(g). In addition, unless a different phone number is provided in item 2i, the 

phone number reported in 2h will appear on the list of plans that pay PBGC premiums posted on pbgc.gov.

i If you would prefer plan Participants with questions about their plan call a phone number other than the 

one reported in item 2h, report the phone number you would like them to use. If this item is left blank, 

PBGC’s website will show the phone number reported in item 2h will be used for the purpose described 

above. 

To keep our records current and enable us to send correspondence to the correct address, you should inform 

us of address changes as soon as they occur. You may do so by contacting us either in writing or by e-mail. 

See Appendix 2 for contact information.

3 Additional plan contact (optional)

Although official correspondence related to premium filings is directed to the Plan Administrator (see item 2), 

some plans choose to provide contact information for another individual as well. In general, the contact 

person identified in this section will be used for questions that are not important enough for official 

correspondence. PBGC may also contact this individual if official inquiries to the Plan Administrator go 

unanswered.
Description of Data Elements

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4 Plan information

a Plan name – Report the complete name of the plan as stated in the plan document. For example, “The ABC 

Company Pension Plan for Salaried Personnel.”

b Premium Payment Year information

(1) Report the date the Premium Payment Year commences and the date it ends. If you are filing for:

 The first year of a New Plan, the Premium Payment Year commencement date (“PYC”) is the plan 

effective date.

 A plan’s final year and the final year is a Short Plan Year, enter the date the Short Plan Year ends.

 A plan that ceased PBGC coverage during the plan year, enter the date the plan year ends, not the 

date the coverage ceased.

(2) Check the appropriate box to indicate whether the plan is a Small Plan for the Premium Payment Year

(See definition of Small Plan in Appendix 1).

(3) If the plan year commencement date has changed since the most recent PBGC filing as a result of a plan 

amendment changing the plan year, enter the adoption date of the plan year change. 

(4) Check the box if plan qualifies to pay a prorated premium for this Premium Payment Year (see “Premium 

Proration” section for rules related to proration).

c Employer Identification Number (EIN) and Plan Number (PN) information.

(1) Report the nine-digit EIN of the Plan Sponsor and the three-digit PN of the plan.

(2) If the EIN and PN for this filing do not both match exactly the EIN and PN reported in the most recent 

premium filing, report both the EIN and PN that were reported in the most recent premium filing. If this 

is the first premium filing for this plan, leave this item blank. 

Please note the following exceptions that apply only if this is an amended filing:

 If item 4c(2) was reported incorrectly in the original filing (i.e., the filing that is being amended), 

provide the correct information in the amended filing.

 If item 4c(2) was reported correctly in the original filing, provide the same information in the 

amended filing.

(3) If the EIN and PN for this filing do not both match exactly the EIN and PN reported in the 2023 Form 

5500, report both the EIN and PN that were reported in the 2023 Form 5500 and attach an explanation. 

If a 2023 Form 5500 was not required, leave this item blank.

d Plan effective date – Report the date the plan became effective.

e Plan type – Indicate whether the plan is a Multiemployer Plan, a Single-employer Plan other than a CSEC 

Plan, or a CSEC Plan. Note that Multiple-employer Plans are considered Single-employer plans for this 

purpose.
Description of Data Elements

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f Information for New or Newly Covered Plans – If this is a New or Newly Covered Plan, check the box and 

complete the rest of item 4f.

(1) Adoption date – Enter the date the plan was adopted.

(2) Date coverage began – Enter the date the plan became covered under Title IV. If the plan has had one or 

more periods of coverage, report the earliest date in the Premium Payment Year when the plan was 

covered under Title IV — not the date when the plan became covered in a prior year. If another plan 

transferred assets or liabilities to this New or Newly Covered Plan, be sure to complete the “Transfers 

from other plans” item (see item 14).

Note for New Plans with Retroactive Effective Dates — PBGC coverage for a New Plan begins on the 

plan’s effective date, regardless of when the plan is adopted.

(3) Continuation Plan – Check the box to indicate whether this New or Newly Covered Plan meets the 

definition of a Continuation Plan (see definition).

Instructions for Part II – Premium Information

5 Flat-rate Premium

a Report the Participant Count Date. See “How to Count Participants” section for special rules relating to New 

Plans, Newly Covered Plans, Mergers and Spinoffs.

b Flat-rate Premium calculation

(1) Applicable rate – Enter the per-participant premium rate. For 2024, the applicable rates are:

 $101 for Single-employer Plans other than CSEC Plans,

 $19 for CSEC Plans, and

 $37 for Multiemployer Plans. 

(2) Participant count – Report the number of Participants covered by the plan on the Participant Count Date

separately for active Participants, terminated vested Participants, retirees and beneficiaries receiving 

payment, and in total. See “How to Count Participants” section.

(3) Flat-rate Premium – Report the product of the Participant Count and the applicable premium rate. If the 

plan year is a Short Plan Year, the required Flat-rate Premium may be a prorated portion of this amount; 

however, the amount reported in this item must reflect a full year’s premium.

Note that you must make a premium filing even if the Flat-rate Premium is $0. This may happen, for example, 

if your plan is a New Plan that grants no past service credits, so that there are no Benefit Liabilities on the 

Participant Count Date. A plan with no Benefit Liabilities has no Participants for premium purposes.

Instructions for Part III – Variable-rate premium information

This Part applies only to Single-employer Plans. Multiemployer Plans should skip to Part IV. CSEC Plans should 

skip to item 7.
Description of Data Elements

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6 Alternative Premium Funding Target Election/Revocation

To be valid, an election must be made in accordance with these instructions and must be filed with PBGC on 

or before the deadline. 

a Election - Check this box to make an election to use the Alternative Premium Funding Target first effective 

for this Premium Payment Year.

b Revocation - Check this box to revoke a prior election to use the Alternative Premium Funding Target that 

was in effect for the Prior Premium Payment Year.

You may elect to use the Alternative Premium Funding Target to determine UVBs instead of the Standard 

Premium Funding Target. Once an election is made, it remains in effect for all subsequent plan years unless 

and until it is subsequently revoked.

You may revoke a prior election only if the Premium Payment Year begins at least five years after the 

beginning of the plan year for which the election was first applicable. Similarly, if you revoke an election, you 

may not make a new election to use the Alternative Premium Funding Target until five years have passed.

If you are not sure if an election is in effect or when an election first took effect, you can find out by viewing 

your account history in My PAA, by clicking the “Account History” link from the Plan Details page.

See “How to Determine Unfunded Vested Benefits” section for more information on elections and 

revocations.

7 Variable-rate Premium 

This item relates to Variable-rate Premium information and applies only to Single-employer Plans. 

In general, for 2024 the Variable-rate Premium is $52 per $1,000, or fraction thereof, of UVBs as of the UVB 

Valuation Date, but no more than $686 times the number of Participants (i.e., the MAP-21 Cap). For CSECs, 

the rate per $1,000 UVBs is $9 instead of $52. For certain plans of small employers, the Variable-rate Premium 

may be capped at an amount lower than the MAP-21 Cap (see item 7b). 

Some Single-employer Plans are exempt from the Variable-rate Premium; others may have a Variable-rate 

Premium of $0. In either case, this section must be completed in accordance with the following instructions.

a Exemptions – A Single-employer Plan may claim an exemption from the Variable-rate Premium if it meets 

the requirements for any of the exemptions described below: 

 New or Newly Covered Small Plan other than Continuation Plan – Your plan qualifies for this exemption 

if it is a New or Newly Covered Plan and a Small Plan, but not a Continuation Plan. See Appendix 1 for 

more information about these terms.

 Standard termination: closing out in current year – Your plan qualifies for this exemption if it makes a 

final distribution of assets in a standard termination during the Premium Payment Year unless it 

engaged in a non-De Minimis Spinoff in the same Premium Payment Year

You may claim this exemption in anticipation of a full distribution by plan year-end even if that hasn’t 

happened by the time you submit the filing. However, if you fail to complete the final distribution by the 

end of the year, the exemption will not apply. In that case, you will need to amend the filing accordingly 

and late payment charges will be assessed on any Variable-rate Premium owed and paid after the 

applicable due date.
Description of Data Elements

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To avoid the possibility of late payment charges arising if the final distribution takes longer than 

expected, consider the alternative approach described in the “Short Plan Years” part of the “Who Must 

File” section.

 Standard termination: proposed termination date in a prior year — Your plan qualifies for this 

exemption if notices of intent to terminate in a standard termination were issued in accordance with 

ERISA section 4041(a)(2), setting forth a proposed termination date before the beginning of the 

Premium Payment Year.

To qualify for this exemption, it is not necessary that the plan make a final distribution of assets during 

the Premium Payment Year. However, this exemption is conditioned on the plan’s ultimately making a 

final distribution of assets in full satisfaction of its obligations under the standard termination. If that 

doesn’t happen, the premium that would otherwise have been required will be due retroactive to the 

applicable due date. In that case, you will need to amend the filing.

 Plans with no vested Participants – Your plan qualifies for this exemption if the plan has no Participants 

with vested benefits as of the UVB Valuation Date. 

 Section 412(e)(3) plans (formerly called 412(i) plans) – Your plan qualifies for this exemption if the plan 

is described in section 412(e)(3) of the Code and regulations thereunder on the UVB Valuation Date.

If an exemption applies, check the applicable box to indicate which exemption applies and skip to item 8. If 

more than one exemption applies, check all applicable boxes. 

b Small-Employer Cap qualification – If the plan qualifies as a small-employer plan, the Variable-rate Premium 

may be capped at an amount lower than the MAP-21 Cap.

Determining whether a plan qualifies for the Small-Employer Cap – For this purpose:

 a plan is a small-employer plan if the aggregate number of employees of all contributing sponsors of the 

plan and all members of the contributing sponsors’ controlled groups, as of the first day of the Premium 

Payment Year, is 25 or fewer, 

 the aggregate number of employees is determined in the same manner as under section 410(b)(1) of the 

Code, taking into account the provisions of section 414(m) and (n) of the Code, but without regard to 

section 410(b)(3), (4), and (5) of the Code, and

 employees are counted as of the first day of the Premium Payment Year, not as of the Participant Count 

Date or the UVB Valuation Date. 

Note that a plan with 25 or fewer Participants does not necessarily qualify for the Small-Employer Cap 

because the eligibility criterion is based on employees, not the Participant Count. For example, if a plan has 

15 Participants, but there are more than 25 employees (taking into account all employees of all contributing 

sponsors of the plan and all members of their controlled groups), the plan does not qualify for the cap.

Also note that a plan with more than 25 Participants might qualify for the cap. For example, consider a 

contributing sponsor with 20 employees, all of whom are Participants in a plan. If the plan also covers 15 

former employees who are either terminated vested or retired, there are 35 Participants in total. This plan 

would qualify for the cap (assuming there are no other contributing sponsors and no controlled group 

members).
Description of Data Elements

Page 42

Reporting requirements – If your plan qualifies for the Small-employer Cap, check the box to report that fact. 

If your plan qualifies for this cap, instead of calculating and reporting both the uncapped Variable-rate 

Premium and the maximum Variable-rate Premium and then paying the lesser of the two amounts, you may

report and pay only the maximum Variable-rate Premium.

If you choose to not report the uncapped Variable-rate Premium, omit all items 7c through 7g and go 

directly to item 7h. Note that if you choose to pay the maximum Variable-rate Premium without 

determining whether it is less than the uncapped Variable-rate Premium, you may pay a larger Variable-rate 

Premium than required.

c Assumptions and methods used to determine Premium Funding Target

(1) Premium Funding Target method – Report whether you are using the Standard Premium Funding Target 

or the Alternative Premium Funding Target to determine UVBs by checking the applicable box (i.e., 

“Standard”, “Alternative”, or “NA, CSEC”). Note that:

 The standard method must be used unless an election to use the alternative method is in effect.

 If an election to use the alternative method is in effect, you must use the alternative method. This is 

the case only if a valid election:

– is made as part of a timely filing for the Premium Payment Year by checking the election box in 

item 6 of Part III, or

– that was made in a prior year has not yet been revoked.

 Filers are encouraged to review prior filings or to review the Account History via the Plan Details

page in My PAA to confirm whether an election to use the alternative method is in effect.

 Checking the alternative box in item 7(c)(1) does not constitute an election. See item 6 instructions.

For additional information on Premium Funding Target methods, see “How to Determine Unfunded 

Vested Benefits” section.

(2) Discount rates – Report the discount rates used to determine the Premium Funding Target. For 

information on which rates to use, see “How to Determine Unfunded Vested Benefits” section.

(3) UVB Valuation Date – Report the UVB Valuation Date for the Premium Payment Year. In the case of a

Small Plan using the Lookback Rule, this date must be the valuation date for the Lookback Year. For any 

other plan this date must be the valuation date for the Premium Payment Year.

Note for Small Plans - For information about whether you should be using the Lookback Rule, see “How 

to Determine Unfunded Vested Benefits” section.

d Premium Funding Target as of UVB Valuation Date

Report the Premium Funding Target (dollars only) calculated as described in the Premium Funding Target 

part of the “How to Determine Unfunded Vested Benefits” section. Report the amount separately for (1) 

active Participants, (2) terminated vested Participants, (3) retirees and beneficiaries receiving payment, and 

(4) the total premium funding target ((1)+(2)+(3)).
Description of Data Elements

Page 43

Estimated Premium Funding Targets – If the Premium Funding Target being reported in this filing is an 

estimate, check the box to report that fact. If you file on an estimated basis, you must ultimately make a 

reconciliation filing using the actual Premium Funding Target (by amending this filing). In the reconciliation 

filing, in addition to reporting the actual Premium Funding Target data, be sure to indicate that the reported 

amount is no longer an estimate by making sure the “estimate” box is no longer checked. See “Correcting 

Errors, Credit Balances and Reconciling Estimates” section for more information. See also the “Late Payment 

Charges” section for information on the automatic late payment penalty relief that may be available to plans 

paying estimated Variable-rate Premiums by the due date and later reconciling. 

e Market value of assets – Report the fair market value of plan assets (dollars only) as of the UVB Valuation 

Date adjusted to reflect contribution receipts as described in the “How to Determine Unfunded Vested 

Benefits” section.

f Unfunded vested benefits – Report the excess (rounded up to the next $1,000), if any, of the Premium 

Funding Target over the fair market value of assets. 

g Uncapped Variable-rate Premium – For CSEC plans, report the product of 0.009 and the amount of UVBs. For 

other plans, report the product of 0.052 and the amount of UVBs.

h Maximum Variable-rate Premium

(1) MAP-21 Cap – Report the product of the Participant Count and $686.

(2) Small Employer Cap – Report the product of $5 and the Participant Count squared. If the plan does not 

qualify for the Small Employer Cap, this item must be left blank.

(3) Maximum Variable-rate Premium – If the plan qualifies for the Small Employer Cap, report the lesser of 

the Small Employer Cap and the MAP-21 Cap. Otherwise, report the MAP-21 Cap.

i Variable-rate Premium – Report the lesser of the maximum Variable-rate Premium and the uncapped 

Variable-rate Premium. If the plan qualifies for the Small Employer Cap and chooses not to report uncapped 

Variable-rate Premium data, report the maximum Variable-rate Premium.

If this is a Short Plan Year of coverage, the required Variable-rate Premium may be a prorated portion of this 

amount; however, the full year’s premium amount must be reported in this item.

Instructions for Part IV – Total Premium Information

8 Premium proration If the plan does not qualify for premium proration, skip to item 9.

If the plan does qualify for premium proration:

 In the case of a Short Plan Year, make sure the dates entered in item 4b(1) regarding the date the plan 

year begins and ends reflect the Short Plan Year, and

 In the case of a Newly Covered Plan for which coverage began after the first day of the plan year, make 

sure the date entered in item 4f(2) is correct.

a Number of months (complete and partial) in the Short Plan Year or Short Coverage Year

Enter the number of complete and partial months in the Short Plan Year or Short Coverage Year. See 

“Premium Proration” section for detailed information about how to count months for this purpose.

b Total premium before proration – Report the sum of the Flat-rate Premium and, if applicable, the Variablerate Premium.
Description of Data Elements

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9 Total premium

 If the plan does not qualify for premium proration, report the sum of the Flat-rate Premium and, if 

applicable, the Variable-rate Premium.

 If the plan qualifies for premium proration, multiply the total premium before reflecting proration by the 

number of months (complete and partial) in the Short Plan Year and then divide by 12. Round to two 

decimal places after completing the calculation. 

If this amount includes cents, report the exact amount (dollars and cents), not a rounded amount.

Instructions for Part V – Payment Information

10 Premium credit

Report the total amount of premium credits available to offset the premium due as follows:

a Enter the sum of any credits used and any payments already made for 2024 (e.g., an estimated Variable-rate 

Premium when amending a filing to reconcile the estimate; see “Correcting Errors, Credit Balances and

Reconciling Estimates” section).

b Enter any overpayment for an earlier plan year that was not refunded or used to offset the premium owed 

for a subsequent plan year.

The plan’s account history via the Plan Details page in My PAA will show whether any payment has already been 

made for 2024 or if any overpayments from a prior year are available to offset the 2024 premium. 

If you are using My PAA to prepare the 2024 filing and a credit is available due to an overpayment for the 2023

plan year, that amount will automatically populate on-screen as a premium credit. Overpayments for earlier 

plan years or payments already made for 2024 will need to be entered manually.

If this amount includes cents, report the exact amount (dollars and cents), not a rounded amount.

11 Amount due

If the total premium due exceeds the total premium credit, subtract the total credit from the total premium 

and report the result as the amount due. This is the amount you owe PBGC. If this amount includes cents, 

report the exact amount (dollars and cents), not a rounded amount.

12 Treatment of overpayment

a If the total premium is less than the total premium credit, subtract the total premium from the total credit 

and report the result as an overpayment. If this amount includes cents, report the exact amount (dollars 

and cents), not a rounded amount.

b If you have an overpayment, you must choose whether to have the overpayment credited towards the 

next year’s premium for the plan or refunded (by electronic funds transfer or check). Report your choice 

by checking the appropriate box.

 Credit - If you choose to use the overpayment as a credit towards next year’s premium for the plan, 

you should claim the overpayment amount as a credit on the next year’s premium filing for the plan.
Description of Data Elements

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 Refund - If you choose to have the overpayment refunded, the quickest way to receive your refund is 

to select the electronic funds transfer option, which we strongly recommend. To facilitate an ACH 

electronic funds transfer, indicate whether the account is a checking account or savings account, and 

provide the bank routing number and account number to which the refund is to be credited. 

Instructions for Part VI – Miscellaneous Information 

13 Final premium filing 

If this is the last premium filing for this plan, check the box to indicate the reason: 

 the plan merged or consolidated with another plan, 

 the plan was trusteed under ERISA section 4042, 

 the plan completed a distribution pursuant to termination, or

 the plan ceased to be covered by Title IV of ERISA.

If the reason is a cessation of coverage, include an explanation as to why you believe the plan is no longer 

covered (e.g., the only remaining Participant is a substantial owner), and if you have not already done so, 

request a determination by submitting a coverage determination form available on PBGC’s “Pension 

Insurance Coverage” web page.

Regardless of the reason for this being the final filing, report the date of the event that led to the cessation 

of the requirement to file. If the reason this is the last premium filing is because:

 of a Merger or Consolidation, report the effective date of the Merger or Consolidation;

 of an involuntary or distress termination, report the effective date of the trusteeship; 

 assets were distributed pursuant to a termination:

- for a Single-employer Plan that completed a standard termination, report the date on which the 

distribution of the plan’s assets in satisfaction of all Benefit Liabilities was completed (the same date 

reported on PBGC Form 501 in item 3a), or 

- for a Multiemployer Plan that distributed all its assets pursuant to ERISA section 4041A, report the 

date the distribution is completed; or

 of a cessation of PBGC coverage, report the date coverage ceased.17F

18

See also “Failure to report a filing as the final premium filing” in the “Correcting Errors, Credit Balances and 

Reconciling Estimates” section.

14 Transfers between plans

Complete this item only if, since the most recent comprehensive premium filing, your plan transferred some, 

or all assets or liabilities to another plan or another plan transferred some, or all assets or liabilities to your

plan.

18 In general, this date can be found on the determination PBGC provides after processing a coverage determination form. 

If you have not received such a determination by the time the filing is due, report the date you believe coverage ceased.
Description of Data Elements

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If your plan was involved in more than one transfer since the most recent comprehensive premium filing, 

provide the following information with respect to each transfer. 

a Check the applicable box to indicate whether your plan was the Transferor Plan or the Transferee Plan.

b Enter the employer identification number and plan number for both plans involved in the transaction. 

Note that My PAA and most private sector software will pre-populate this information with respect to 

your plan.

c Check the applicable box to indicate the type of transfer. See Appendix 1 for definitions of Merger, Spinoff, 

and Consolidation for premium purposes. Check the “Other” box if:

• If your plan is the Transferee Plan and you have no way of determining whether the Transferor Plan 

ceased to exist in connection with the transaction, or

• If the transfer is the result of a reciprocity arrangement where assets and liabilities are transferred 

between two plans when an employee changes locations or changes status (e.g., from Salaried to 

Hourly and as a result becomes covered by another plan). For these types of transfers, you may 

aggregate all such transfers between the same two plans and report as if they all occurred on the 

same date. 

d Enter the date the transfer occurred. Note that the date of a transfer is determined based on the facts 

and circumstances of the particular situation. (For transfers subject to section 414(l) of the Code, report 

the date determined under 26 CFR 1.414(l)-1(b)(11).) 

e Additional information for certain transactions. Complete this item only if the transfer occurred on the first 

day of the plan year and the plan is not a New Plan

(1) Check the applicable box to indicate whether the transfer was De Minimis. In general, this item 

should be completed from the perspective of your plan. However, if some, but not all, of the assets 

and liabilities of another plan were transferred into this plan, if this plan is the Transferee Plan, check 

the “De Minimis” box if, from the perspective of the Transferor Plan, the Spinoff was De Minimis.

(2) Complete this item only if the plan is reporting that another plan was merged into this plan at the 

beginning of this plan’s plan year (i.e., this plan is the Transferee Plan) and the Merger was 

De Minimis.

Check the “yes” box if this plan’s assets, immediately before the Merger were less than the total 

assets transferred to this plan in the Merger.

The section on “Spinoffs, Mergers and Consolidations” contains examples of how this item is completed in 

various scenarios.

15 Participation freeze

If, as of the beginning of the Premium Payment Year, participation is limited to Participants who were 

covered by the plan as of a specified date (i.e., the plan is closed to new entrants), enter the date the plan 

became closed to new entrants.
Description of Data Elements

Page 47

16 Accrual freeze 

If, as of the beginning of the Premium Payment Year, the plan is partially or totally frozen for benefit accrual 

purposes, enter the date the freeze became effective and indicate the nature of the freeze by reporting 

whether (1) both pay and service are frozen for all Participants, (2) both pay and service are frozen for some

Participants, (3) for all Participants, service is frozen, but pay is not, (4) for some Participants, service is 

frozen, but pay is not, or (5) some other type of accrual freeze is in effect (in which case you must provide a 

description of the freeze).

If more than one description applies (for example, if pay and service are frozen for employees at location X 

and only service is frozen for employees at location Y), select “Other” and provide a description. 

If more than one freeze has occurred, report the date and nature of the most recent freeze. 

17 Risk transfer activity – Do not complete this item if this is the final filing for the plan. 

a Lump Sum Windows – If the plan provided one or more Lump Sum Windows for which the election 

period ended during the Prior Premium Payment Year, enter the requested information with respect to 

Participants eligible to elect a lump sum under the window. For this purpose: 

 Disregard lump sums offered: 

- In the course of routine plan operations, 

- In conjunction with a plan termination, 

- Upon a Participant’s separation from service, or 

- As part of an incentive program to encourage active Participants to retire early (commonly called 

an early retirement window). 

 Disregard lump sums paid under mandatory cash out provisions.

 Include beneficiaries of deceased Participants who were eligible to elect a lump sum in conjunction 

with the Lump Sum Window.

 A Participant eligible for a Lump Sum Window whose offer letter is undeliverable may be excluded 

from the “Participants eligible to elect a lump sum” count. 

 If the exact counts are not readily available, reasonable estimates based on readily available plan 

records may be reported. 

 Disregard Lump Sum Windows for which the election period ended after the end of the Prior Premium 

Payment Year. 

b Annuity Purchases - If the plan purchased annuities for any Participants during the Prior Premium 

Payment Year, enter the requested information with respect to those Participants. For this purpose: 

 Do not include annuity contracts: 

- Purchased in the course of routine plan operations, 

- Purchased in conjunction with a plan termination, or 

- That remains an asset of the plan (commonly called a “buy-in”). 

 Include beneficiaries of deceased Participants for whom an annuity was purchased.

 If the exact counts are not readily available, reasonable estimates based on readily available plan 

records may be reported. 
Description of Data Elements

Page 48

18 Amended filings – Complete this item only if this is an amended filing. 

a If either the first day or the last day of the Premium Payment Year reported in this amended filing (item 

4b(1)) differs from what was reported in the original filing (i.e., the filing that is being amended), provide 

the dates that were reported in the original filing.

b If the EIN and PN reported in this amended filing (item 4c(1)) are not both the same as what was reported 

in the original filing (i.e., the filing that is being amended), report the EIN and PN from the original filing.

c If this is an amended filing for a reason other than reconciling an estimated Variable-rate Premium and

the amended filing shows a lower premium than the amount that was originally reported, you must 

provide an explanation of the specific circumstances or events that caused the reduction in premium.

19 Disaster Relief – Complete this item only if the plan is eligible for disaster relief for the Premium Payment 

Year.

a Enter the identifier for the IRS Disaster Relief News Release applicable to your plan. For example, if the 

applicable News Release is labelled CA-2024-01, enter CA202401.

b If the address of the Plan Administrator reported in this filing is in the disaster area covered by the IRS 

News Release identified in item 19a, check yes. Otherwise, check no. 

c If the answer to item 19b is yes, this item may be left blank. Otherwise, enter the name, address and role 

(e.g. TPA, Enrolled Actuary) of the person affected by the disaster.

Instructions for Part VII – Certifications

20 Plan Administrator Certification

All of the information reported in this filing must be certified by the Plan Administrator. Be sure to provide 

the Plan Administrator’s name, the telephone number, email address, and the certification date.

Although filings must be submitted electronically, procedures have been established under which the Plan 

Administrator may manually sign a computer-generated copy of the “form” instead of signing it electronically 

within My PAA. If the Plan Administrator chooses this method of certifying the filing:

 For My PAA screen-prepared filings, a person assigned the role of “plan administrator's representative

(Plan Admin Rep)” must electronically certify within My PAA that the plan administrator has manually 

certified the filing.

 For software-prepared filings that are uploaded into My PAA, the name, email and phone number of the 

plan administrator who manually certified (or will be manually certifying) the filing is reported in the 

certification section of the filing (within the XML filing data). 

Although the filing may not be submitted until the plan administrator has manually signed and certified 

the filing, for uploaded filings, the plan certification date (i.e., the date the plan administrator manually 

certified the filing) may be omitted if that date is not known at the time the XML file is created. Manually 

certified copies of filing information are subject to audit and must be retained with plan records for six 

years from the due date of the filing. After a paper copy of premium information is certified, it may be 

converted to electronic form for preservation in the plan records subject to the requirements of 

subpart E of the PBGC’s regulation on Filing, Issuance, Computation of Time, and Record Retention (29 

CFR Part 4000).
Description of Data Elements

Page 49

See the certification instructions on PBGC’s My PAA online demo web page for additional information about

the Plan Administrator certification requirement.

21 Enrolled Actuary Certification

An enrolled actuary must certify the Variable-rate Premium calculation unless:

 The plan is a Multiemployer Plan (and thus, there is no Variable-rate Premium).

 The plan is a Single-employer Plan and is either:

- exempt from the Variable-rate Premium, or

- omitting the variable rate premium information in items 7c through 7g because the plan is eligible 

for the Small Employer Cap and is paying the maximum Variable-rate Premium.

Be sure to provide all of the required information related to the enrolled actuary (i.e., name, firm, telephone 

number, enrollment number, and if the enrolled actuary has an e-mail address, email address).

The actuary must follow the certification instructions for the electronic filing method that is used to make 

the filing. See the certification instructions on PBGC’s My PAA online demo web page for additional 

information about the Enrolled Actuary certification requirement.
Late Payment Charges 

Page 50

If you file a premium payment after the due date, we will bill the plan for late charges. Late charges include both 

interest and penalty charges. The charges are based on the outstanding premium amount due on the due date. 

Late Payment Interest Charges

The late payment interest charge is set by ERISA, and we cannot waive it. Interest accrues at the rate imposed 

under section 6601(a) of the Code (the rate for late payment of taxes) and is compounded daily. These rates are 

published by IRS quarterly and are also posted on PBGC’s “Interest Rates and Factors” web page.

Late Payment Penalty Charges

Late payments are generally subject to a penalty of 21⁄2% of the late amount per month (or partial month) late, 

capped at 50% of the late amount. However, in the event a plan discovers and corrects an underpayment before 

PBGC sends written notice that there is or may be a premium delinquency, the 21⁄2% rate is reduced to 1⁄2% and 

the cap is reduced from 50% to 25%.

The written notices mentioned above include, but are not limited to:

 Past Due Filing Notice (PDFN) — This notice is sent if we expect to receive a premium filing from the Plan but 

do not. These notices are sent to the Plan Administrator at the address reported on the most recent filing.

 Notice of Filing Error (NFE) — This notice is sent if an initial review of a premium filing indicates an error or 

inconsistency that must be corrected before the filing can be processed. If you receive a Notice of Filing 

Error, you must amend your filing to correct the error. If we do not receive an amended filing within 30 days, 

we will send a PDFN (see above).

 Statement of Account (SOA) — If we receive a filing, but the payment is late or less than the reported 

amount owed, we will send a Statement of Account. A SOA is, in essence, an invoice for premium, penalty, 

and interest amounts owed to PBGC. To ensure that the amount due does not increase, the premium and 

interest must be paid within 30 days of the SOA's issue date. 

 Notice of a Premium Compliance Evaluation (PCE) — This notice is sent if we select your premium filing to 

assess the accuracy of the reported information. See the Premium Filings page on our web site for further 

information. 

Penalty Waivers

Case-by-Case Waivers

If you receive a Statement of Account (“SOA”) that includes a penalty charge, but you believe there is a reason 

why all or a portion of the penalty should be waived (e.g., reasonable cause), you may request a waiver.

Information about what constitutes reasonable cause as well as information about other situations where a 

penalty waiver might be warranted can be found in § 21 of the appendix to PBGC’s premium payment 

regulation, 29 CFR Part 4007, available on PBGC’s “Legal Resources” web page.

The instructions and timeframe for requesting a waiver will be provided in the SOA. Be sure to follow the 

instructions carefully. Requests that are submitted late will not be considered.
Late Payment Charges 

Page 51

Hardship (i.e., “Statutory”) Waivers

If, before the filing due date, you can show substantial hardship and that you will be able to pay the premium 

within 60 days after the filing due date, you may request that we waive the late payment penalty charge. If we 

grant your request, we will waive the late payment penalty charge for up to 60 days. To request a waiver, 

contact PBGC at least 30 days before the filing due date. Be sure to include specific information and documents 

to demonstrate both that it will be a substantial hardship to make the payment on or before the filing due date 

and that you will have the ability to make the payment within 60 days after the filing due date.

Automatic Penalty Waiver for Premiums paid Within Seven Days of Due Date

If the sole reason a late payment penalty charge applies is because a premium was paid in full after the due 

date, but within seven calendar days of the due date, the late payment penalty charge will automatically be 

waived.

Automatic Penalty Waiver for Certain Typically Compliant Plans

PBGC will automatically waive 80% of the penalties assessed at the 21⁄2% rate if the plan: 

 Corrects the underpayment within 30 days of PBGC’s initial notice, and

 Has a good premium compliance history.

For this purpose, a “good premium compliance history” generally means that the plan paid required premiums 

timely for the five plan years immediately preceding the Premium Payment Year. In addition, if, during the 

5 -year period, the plan paid its premium late, but was not required to pay a late payment penalty (e.g., the 

penalty was waived), the plan is treated as paying timely for that year.

Automatic Penalty Waiver for Certain Late Variable-rate Premiums

As explained in the “When to File” section, in rare circumstances (e.g., a mid-year Merger or change in actuary), 

the Premium Funding Target might not be calculated or finalized by the premium due date. PBGC allows plans in 

this situation to file timely and pay an estimated Variable-rate Premium by the due date and then submit an 

amended filing at a later date to reconcile the actual Variable-rate Premium with the estimate.

Because a plan’s full Variable-rate Premium (not merely an estimate) is due by the due date, if the full amount is 

not paid by that date, the plan will be subject to late payment interest charges and may also be subject to late 

payment penalty charges.

If the actual Variable-rate Premium is greater than the estimate, penalties for late payment will be waived if:

 the reconciliation filing is made and any additional required Variable-rate Premium paid by the end of the 

sixth calendar month that begins on or after the premium due date (generally April 30th after year-end for 

calendar year plans), and

 by the premium due date, you report:

- the fair market value of the plan’s assets, and

- an estimate of the Premium Funding Target that the enrolled actuary certifies is reasonable and that:

o takes into account the most current data available to the enrolled actuary; 

o has been determined in accordance with generally accepted actuarial principles and practices; 

o uses the calculation methodology (alternative or standard) in effect for the plan year; and
Late Payment Charges 

Page 52

 by the premium due date, you pay at least the amount of Variable-rate Premium determined from the value 

of assets and estimated Premium Funding Target so reported.

Note that this waiver applies only to estimated Premium Funding Targets, not estimated asset values. If the 

asset value reported in the reconciliation filing differs from what was reported in the original (i.e., estimated) 

filing, this automatic penalty relief will be lost. However, PBGC will consider a request for an appropriate penalty 

waiver in such a situation and, in acting on the request, will consider such facts and circumstances as the reason 

for the mistake, whether assets were overstated or understated, and, if assets were overstated, the extent of 

the overstatement.

If you know the final Premium Funding Target by the time the Variable-rate Premium is due, you should pay the 

amount owed by that date. If you do so, you will avoid the interest charge and any penalty charge. If you report 

that you are making a filing based on an estimated Premium Funding Target, you will be required to make an 

amended filing reflecting the actual Premium Funding Target by the date the Variable-rate reconciliation filing is 

due.

Minimizing Late Payment Charges 

If you cannot make a filing by the due date because you are having difficulty determining some of the required 

information, you can minimize late payment charges by submitting payment (the amount due or an estimate) 

without submitting the certified filing. As of the date these instructions were issued, when submitting a payment 

without a corresponding filing, the payment has to be made outside of My PAA, either via www.pay.gov, or by 

check or electronic payment.

Making a premium payment without an accompanying premium information filing (i.e., EIN, PN, PYC) may cause 

significant delay in providing a statement of account for the plan. However, when the information filing is 

ultimately made, the payment will be credited as of the date it was filed and thus stop the accrual of late 

payment charges on the amount paid. 

Saturday, Sunday, and Federal Holidays 

As explained in the “When to File” section, if your premium filing due date falls on a Saturday, Sunday or Federal 

Holiday, it is extended automatically to the next business day. However, if your premium payment is filed after 

the extended due date, interest and penalties will be computed from the actual (unextended) due date. 

Example –The Normal Due Date for a plan with a plan year beginning on April 1, 2023 would normally be 

Monday, January 15, 2024. Because that day is a federal holiday, the due date is Tuesday, January 16, 2024. If 

the filing is made after January 16 th then late payment charges, if applicable, will be computed from Monday, 

January 15, 2024, not January 16 th.
Correcting Errors, Credit Balances and Reconciling Estimates

Page 53

Correcting errors

Making Payment Without Filing Information

If you make a premium payment without filing the related premium information, file the information as soon as 

possible to get proper credit for your payment and minimize any late filing penalty. Follow the instructions in 

this document or on PBGC’s “Premium Filing Payment and Instructions” web page for identifying your payment 

so that we can associate it with your information filing.

Note that PBGC may assess a penalty under ERISA section 4071 for failure to furnish premium-related 

information by the required due date.

Filing Information Without Making Required Payment

If you make a filing of premium information without making a required payment, send the payment as soon as 

possible to minimize late payment charges. Follow the instructions in this document or in My PAA for identifying 

your payment so that we can associate it with your information filing.

Failure to report a filing as the final premium filing

If you make a premium filing that is a “Final premium filing” as described in item 13 of the Comprehensive 

Premium Filing instructions, and you do not provide the information required by item 13, you must make an 

amended filing if the event referred to in item 13 occurred before you made your original filing, unless:

 The event was a distribution of assets pursuant to plan termination and was reported on PBGC Form 501, or

 The event was a Merger into or Consolidation with another plan and was reported on a premium filing for 

the surviving plan.

If you make a premium filing that is a “Final premium filing” as described in item 13 of the Comprehensive 

Premium Filing instructions, and you do not provide the information required by item 13 because the event 

referred to in item 13 has not yet occurred when you make the filing, you are not required to make an 

amended filing. However, to avoid the need for correspondence to establish why you are not making any more 

premium filings, we recommend that you contact us to report the event, unless:

 The event was a distribution of assets pursuant to plan termination and is being reported on PBGC 

Form 501, or

 The event was a Merger into or Consolidation with another plan and is being reported on a premium filing 

for the surviving plan.

Even if an amended filing is not required, you may want to make one where the plan has made a distribution of 

assets pursuant to plan termination, because that event may enable you to reduce the premium through 

proration and request a refund as part of the amended filing.

Alternatively, because our system automatically prorates premiums for plans in this situation based on the 

information reported on PBGC Form 501 and updates the plan’s account history to reflect any overpayment, in 

lieu of submitting an amended filing, you may request a refund of such overpayment by utilizing the "Submit 

Request" link available on the My PAA Plan Details page or by sending an email to premiums@pbgc.gov.

For more information about submitting requests via My PAA, see PBGC’s My PAA online demo web page.
Correcting Errors, Credit Balances and Reconciling Estimates

Page 54

Amending Filings 

If, after submitting a filing, you discover an error has been made (e.g., reported information is incorrect), you 

must amend the filing to report the correct information even if the correction has no impact on the premium 

amount. A filing can be amended by resubmitting the filing with the corrected information. Be sure to indicate 

that the filing is an amendment to a previously submitted filing (see “Description of Data Elements” sections). 

In the amended filing, report all of the required information, including information that was correct in the 

original filing (i.e., the filing that is being amended). Include as credits all the credits you previously claimed 

increased by the amount you paid with your most recent filing and reduced by any refund you requested.

If the originally reported premium:

 was too low, the additional premium due will equal the excess of the revised total premium amount over 

the revised total credit. Pay the additional premium due when you submit your amended filing. If the 

additional premium is paid after the premium due date, late payment interest charges will apply and late 

payment penalty charges may apply. You will receive an invoice for these charges after your amended filing 

is received. You may include payment of anticipated late payment charges when you pay the additional 

premium, but the amount reported on the amended filing should reflect only the additional premium due.

 was too high, the overpayment will equal the excess of the revised total credit over the revised total 

premium. You must indicate whether you want the overpayment refunded or applied to the next year’s 

premium for the plan. We recommend that small credit amounts be carried over to the next plan year.

Please verify the credit amount by either reviewing the plan’s account history in My PAA or by contacting our 

Premium Customer Service Center. Then, simply enter the relevant amount under “Premium Credits” in the 

next year’s premium filing. See line 10b on the illustrative form in the “Data to be Submitted” section.

If you prefer a refund by electronic funds transfer (ACH), provide the necessary information in the applicable 

section of the amended filing; we will make the transfer through the ACH system. 

With either option, the overpayment will appear as an “Amount Overpaid” on your plan’s account history 

until it is refunded or used to satisfy a future year’s premium. See section below on Premium Credit 

Balances.

Required explanation if premium amount decreases

If you amend a comprehensive filing, for a reason other than reconciling an estimated Variable-rate Premium 

and the amended filing shows a lower premium than the amount that was originally reported, you must provide 

an explanation of the specific circumstances or events that caused the reduction. For example, if your original 

comprehensive filing’s Participant Count included employees at a division that is not covered by the plan, you 

would explain why the employees were erroneously counted as Participants and how the error was discovered.

Amending a prior year’s filing

Note that if you are amending a filing for an earlier year, you must follow the instructions for that year except 

that current mailing and electronic funds transfer (EFT) addresses should be used instead of the addresses that 

were included in the instructions for the original filing (i.e., the filing that is being amended). Prior year 

instructions are available on PBGC’s “Premium Filing” web page.
Correcting Errors, Credit Balances and Reconciling Estimates

Page 55

Premium Credit Balances

Premium credit balances, whether resulting from an amended filing or any overpayment, are shown on plans’ 

account histories and can be viewed in My PAA at any time. We recommend you review your plan’s account 

history before you file to ensure that any available credits from the prior plan year have been used. If you have a 

credit from two or more years prior to the Premium Payment year, you will need to contact the Premium 

Customer Service Center in order to use it (See Appendix 2).

Note that an overpayment for one plan cannot be applied to another plan’s underpayment. 

A plan administrator may request that a premium credit balance be refunded or be credited against the next 

year’s premium. Such requests must be made within the statutory limitation period (generally six years from the 

date the payment that resulted in the credit balance was made).

Reconciling Estimates

For plans that filed an estimated Variable-rate Premium, the reconciliation is made by amending the filing that 

included the Variable-rate Premium estimate. This reconciliation filing serves to finalize a previously estimated 

Premium Funding Target; it does not afford an opportunity to elect to use the alternative method after the due 

date for such election (or to revoke a prior election after the due date for such revocation). See the instructions 

for item 7d in the “Description of Data Elements” section for additional information on how to reconcile an 

estimated Variable-rate Premium.

Failure to reconcile these estimates in a timely manner will result in late payment charges if the estimate to be 

reconciled was too low. PBGC may also assess penalties under ERISA section 4071 for failure to reconcile 

estimated premium filings by the reconciliation due date. 
Recordkeeping Requirements and PBGC Audits

Page 56

Recordkeeping requirements

Plan Administrators are required to retain all plan records that are necessary to establish, support and validate 

the amount of any PBGC premium required to be paid and any information required to be reported. The records 

must include calculations and other data prepared by an enrolled actuary, the Plan Sponsor, and an employer 

required to contribute to the plan with respect to its employees; or for a plan described in section 412(e)(3) of 

the Code, by the insurer from which the insurance contracts are purchased. The records must be kept for six 

years after the premium due date.

Records that must be retained include, but are not limited to, records that establish the number of plan 

Participants and the amount of UVBs on which the Variable-rate Premium is based. For this purpose, the term 

“records” includes, but is not limited to: plan documents, Participant data records, personnel and payroll 

records, actuarial tables, worksheets, and reports, records of computations, projections, and estimates, benefit 

statements, disclosures, and applications, financial and tax records, insurance contracts, records of plan 

procedures and practices, and any other records, whether in written, electronic, or other format, that are 

relevant to the determination of the amount of any premium required to be paid or any premium-related 

information required to be reported.

Records retained must be made available or submitted to PBGC promptly upon request. If a record to be 

produced for PBGC inspection and copying exists in more than one format, it must be produced in the format 

that PBGC specifies.

PBGC Audits

We may audit any premium filing; inspect and copy any records that are relevant to the determination of the 

amount of any premium required to be paid and any premium-related information required to be reported; and 

require disclosure and demonstration of any system used to determine any premium required to be paid or 

premium-related information required to be reported, so that PBGC can assess the system’s effectiveness and 

reliability.

If we determine upon audit that the full amount of the premium due was not paid, late payment interest 

charges under § 4007.7 of the Premium Regulations and late payment penalty charges under § 4007.8 of the 

Premium Regulations will apply to the unpaid balance from the premium due date to the date of payment (see 

“Late Payment Charges” section for more information on penalties and interest for late payment of premiums).

If, in our judgment, the plan’s records fail to establish the number of Participants with respect to whom 

premiums were required, we may rely on data we obtain from other sources (including the Internal Revenue 

Service and the Department of Labor) for presumptively establishing the number of plan Participants for 

premium computation purposes. Similarly, if, in our judgment, the plan’s records fail to establish the UVB

amount reported in the premium filing, we may rely on data we obtain from other sources for estimating the 

UVBs for premium computation purposes.

In addition to penalties for late payment of premiums, we may assess a penalty under ERISA section 4071 for 

failure to furnish premium-related information by required due dates.
Appendix 1 – Definitions

Page 57

Definitions for terms shown in capital letters throughout the instructions are shown below.

“Alternative Premium Funding Target” – see “Premium Funding Target”

“Benefit Liabilities” means all liabilities with respect to employees and their beneficiaries under the plan (within 

the meaning of Code section 401(a)(2)). Thus, Benefit Liabilities include liabilities for all accrued benefits, 

whether or not vested. In addition, a plan’s Benefit Liabilities include liabilities for ancillary benefits not directly 

related to retirement benefits, such as disability benefits not in excess of the qualified disability benefit, life 

insurance benefits payable as a lump sum, incidental death benefits, or current life insurance protection (see 

Treasury Regulation § 1.411(a)-7(a)(1)).

“Code” means the Internal Revenue Code of 1986, as amended.

“Comprehensive Premium Filing” is the term used to describe the premium filing, regardless of whether the 

filing is the first filing for the plan year, an amended filing, or a reconciliation filing.

“Consolidation” means a transaction in which two or more plans transfer all of their assets and liabilities to a 

New Plan and, as a result, cease to exist (because the Transferor Plans become part of the new Transferee Plan). 

It differs from a Merger because in a Merger, the Transferee Plan existed before the transaction. In a 

Consolidation, the Transferee Plan is a New Plan that is created in the Consolidation. Thus, the plan that exists 

after a Consolidation follows the premium filing rules for New Plans.

“Continuation Plan” means a New Plan resulting from a Consolidation or Spinoff that is not De Minimis.

“CSEC Plan” means a cooperative and small-employer charity plan (as defined in section 210(f)(1) of ERISA) that 

is subject to the alternative funding standards of section 306.

“De Minimis” with respect to a Merger or Spinoff means a transaction described as de minimis in regulations 

under section 414(l) of the Code (for single-employer plans) or in part 4231 of this chapter (for multiemployer 

plans). With respect to a pre-existing Transferee Plan to which another plan transfers, some, but not all, assets 

and liabilities, the transaction is considered De Minimis from the perspective of the Transferee Plan if the Spinoff 

is De Minimis from the perspective of the Transferor Plan. 

“EIN” means Employer Identification Number. It is always a nine-digit number assigned by the Internal Revenue 

Service for tax purposes.

“ERISA” means the Employee Retirement Income Security Act of 1974, as amended (29 U.S.C. 1001 et seq.).

“Flat-rate Premium” means the portion of the premium determined by multiplying the flat premium rate by the 

number of Participants in the plan on the Participant Count Date. 

“Form 5500 Series” means Form 5500, Annual Return/Report of Employee Benefit Plan, jointly developed by the 

Internal Revenue Service, the Department of Labor, and PBGC. 

“Interest Rate Stabilization Rules” means the rules under which the volatility of certain discount rates used for 

funding purposes is limited by constraining them within a specified corridor as provided in ERISA 303(h)(2)(C)(iv).

“Lookback Rule” means the provision under which the Variable-rate Premium for the Premium Payment Year is 

determined based on UVBs for the plan year Prior Premium Payment Year instead of the Premium Payment 

Year.

“Lookback Year” means the Prior Premium Payment Year.

“Lump Sum Window” means a temporary opportunity to elect a lump sum in lieu of future annuity payments 

that is offered to individuals meeting specified criteria who would not otherwise be eligible to elect a lump sum.
Appendix 1 – Definitions

Page 58

“MAP-21 Cap” means the per-Participant cap on the Variable-rate Premium as provided in The Moving Ahead 

for Progress in the 21st Century Act.

“Merger” means a transaction in which one or more plans transfer all of their assets and liabilities to an existing 

plan and, as a result, cease to exist (because the Transferor Plan(s) become part of the Transferee Plan). It 

differs from a Consolidation because in a Consolidation, the Transferee Plan did not exist before the transaction. 

In a Merger, the Transferee Plan is an existing plan and follows the rules for preexisting, ongoing plans. 

“Multiemployer Plan” (subject to the provisions of ERISA sections 3(37)(E) and (G) and 4303, dealing with 

elections to be treated or not to be treated as a Multiemployer Plan) means a plan:

 to which more than one employer is required to contribute,

 which is maintained pursuant to one or more collective bargaining agreements between one or more 

employee organizations and more than one employer, and

 which satisfies such other requirements as the Secretary of Labor may prescribe by regulation. 

For purposes of determining whether a plan is a Multiemployer Plan or a Single-employer Plan, all trades or 

businesses (whether or not incorporated) that are under common control are considered to be one employer.

“Multiple-employer Plan” means a plan to which more than one employer contributes that is not a 

Multiemployer Plan. 

“My PAA” means “My Plan Administration Account,” PBGC’s electronic premium filing application.

“New or Newly Covered Plan” means a plan that is either a New Plan or a Newly Covered Plan. In some cases, 

the term “New and Newly Covered Plan” is used for the same purpose.

“New Plan” means a plan that did not exist before the Premium Payment Year. This includes a plan resulting 

from a Consolidation or Spinoff. A plan that meets this definition is considered to be a New Plan even if the plan 

constitutes a successor plan within the meaning of ERISA section 4021(a).

A plan adopted during the Premium Payment Year with an effective date retroactive to a date in the Prior 

Payment Year is considered a New Plan for the Prior Premium Payment Year, not the Premium Payment Year.

“Newly Covered Plan” means a plan that becomes covered by title IV of ERISA during the Premium Payment 

year and that existed as an uncovered plan immediately before the first date of the Premium Payment Year on 

which it was a covered plan.

“Normal Premium Due Date” means the date premiums are due unless some special situation applies (i.e., a 

change in plan year, first time filing, or a standard termination). See “When to File” section.

“Participant” of a plan means an individual (whether active, inactive, retired, or deceased) with respect to 

whom the plan has Benefit Liabilities. See “How to Count Participants” section for more information.

“Participant Count” means the number of Participants on the Participant Count Date. See “How to Count 

Participants” section for more information.

“Participant Count Date” means the date on which Participants are counted for purposes of determining the 

Flat-rate Premium, the MAP-21 Cap on the Variable-rate Premium, whether the plan is a Small Plan, and, if 

applicable, the Small Employer Cap on the Variable-rate Premium. In general, it is the last day of the Prior 

Premium Payment Year, but there are some exceptions. See “How to Count Participants” section for more 

information.
Appendix 1 – Definitions

Page 59

“Plan Administrator” means:

 the person specifically so designated by the terms of the instrument under which the plan is operated; or

 if an administrator is not so designated, the Plan Sponsor.

“Plan Adoption Date” means the date on which a plan was formally adopted.

“Plan Sponsor” is determined as follows:

 For a Single-employer Plan with:

- one contributing sponsor, the Plan Sponsor is the contributing sponsor; 

- two or more contributing sponsors that are all in a single controlled group, the Plan Sponsor is the 

parent of the controlled group or, if there is no parent, the largest member of the controlled group 

(whether or not the parent or largest member is a contributing sponsor);

- two or more contributing sponsors that are not all in a single controlled group, the Plan Sponsor is 

determined as follows: first identify the controlled group or contributing sponsor that is not in a 

controlled group, that has the most Participants in the plan. If you identify a contributing sponsor that 

is not in a controlled group, the Plan Sponsor is that contributing sponsor. But if you identify a 

controlled group, then the Plan Sponsor is the parent of that controlled group or, if there is no parent, 

the largest member of that controlled group (whether or not the parent or largest member is a 

contributing sponsor).

 For a Multiemployer Plan, the Plan Sponsor is the association, committee, joint board of trustees, or other 

entity that establishes or maintains the plan.

“PN” means Plan Number. This is always a three-digit number. The employer maintaining the plan assigns this 

number to distinguish among employee benefit plans established or maintained by the same employer. An 

employer usually starts numbering pension plans at “001” and uses consecutive Plan Numbers for each 

additional plan. Once a PN is assigned, always use it to identify the same plan. If a plan is terminated, retire the 

PN — do not use it for another plan.

“Premium Funding Target” is the liability measure used to determine the Variable-rate Premium. This is similar 

to the funding target that is used to determine the minimum funding requirement except that only vested 

benefits are taken into account. The discount rates used to determine this amount vary depending on which 

calculation method is used (standard or alternative):

 “Standard Premium Funding Target” means a Premium Funding Target determined using the ERISA section 

4006(a)(3)(E)(iv) segment rates.

 “Alternative Premium Funding Target” means a Premium Funding Target determined using ERISA section 

303 (i.e., funding) discount rates, but without regard to the MAP-21 Stabilization Rules. See “How to 

Determine Unfunded Vested Benefits” section for additional information related to the election and use of 

the Alternative Premium Funding Target.

“Premium Payment Year” means the plan year for which the premium is being paid. For example, because this 

document relates to premium filings for plan years beginning in 2024, all references to Premium Payment Year 

relate to plan years beginning in 2024.

“Premium Regulations” means PBGC’s regulations on Premium Rates and Payment of Premiums (29 CFR Parts 

4006 and 4007). The premium filing procedures (including the My PAA electronic filing application, paper 

instructions, and forms) are prescribed under and implement the Premium Regulations.
Appendix 1 – Definitions

Page 60

“Prior Premium Payment Year” means the plan year immediately preceding the Premium Payment Year.

“Schedule SB” means Schedule SB to the Form 5500 Series.

“Short Plan Year” means a plan year of less than 12 full months.

“Short Coverage Year” means a plan year in which the plan was not covered by PBGC for a portion of the year.

“Single-employer Plan” means any plan that is not a Multiemployer Plan. A Single-employer Plan includes a 

Multiple-employer Plan. For purposes of determining whether a plan is a Multiemployer Plan or a Singleemployer Plan, all trades or businesses (whether or not incorporated) that are under common control are 

considered to be one employer.

“Small-Employer Cap” means the maximum Variable-rate Premium due for certain plans of small employers, 

generally employers with 25 or fewer employees. For these plans, the maximum Variable-rate Premium is the

lesser of the product of $5 and the Participant Count squared and the MAP-21 cap.

“Small Plan” means a plan:

 With a Participant Count for the Premium Payment Year of not more than 100, or

 With a funding valuation date for the Premium Payment Year, determined in accordance with ERISA section 

303(g)(2), that is not the first day of the Premium Payment Year.

“Spinoff” means a transaction in which the Transferor Plan transfers only part of its assets and/or liabilities to 

the Transferee Plan. The Transferee Plan may be a New Plan that is created in the Spinoff, or it may be a 

preexisting plan that simply receives part of the assets and/or liabilities of the Transferor Plan.

“Standard Premium Funding Target” – see “Premium Funding Target”

“Transferee Plan” means a plan that receives assets and/or liabilities from another plan in a transfer (e.g., 

Spinoff, Merger, or Consolidation).

“Transferor Plan” means a plan that gives assets and/or liabilities to another plan in a transfer (e.g., Spinoff, 

Merger, or Consolidation).

“UVB Valuation Date” means the date on which UVBs are determined. This date is the plan’s funding valuation 

date determined in accordance with ERISA section 303(g)(2) for:

 In the case of a plan using the Lookback Rule, the Lookback Year, or

 In the case of any other plan, the Premium Payment Year.

”UVBs” means unfunded vested benefits, the term used to describe the underfunding measure on which the 

Variable-rate Premium is based.

“Variable-rate Premium” means the portion of the Single-employer premium based on a plan’s UVBs. 

“We” or “us” refers to the Pension Benefit Guaranty Corporation.

“You” or “your” refers to the Plan Administrator.
Appendix 2 – Contact information

Page 61

 For premium-related inquiries and requests, including premium filing questions, requests for instructions, 

address changes, requests for refunds (that are not submitted with premium filings), and requests for 

penalty waivers, contact our premium customer service center using one of these following options:

─ Preferred options:

Utilize the “Ask a Question” tool within My PAA. 

─ Send electronic inquiry/request via My PAA’s "Submit a Request" link available on the Plan Detail page.

Submitting the request this way has many benefits (e.g., automatically generated confirmation email, 

ability to check the status of a requests).

For more information about submitting requests via My PAA, see PBGC’s My PAA online demo web 

page.

─ Other options:

o Mail or private delivery service: Send to the address for premium correspondence posted on the 

“Contact Us for Practitioners” web page.

o Call: 1-800-736-2444 or 202-326-4242 and select option 2 (premiums). 

o E-mail: premiums@pbgc.gov

 For questions about coverage determinations or plan terminations:

─ Call: 1-800-736-2444 or 202-326-4242 and press “0”

─ E-mail: standard@pbgc.gov or coverage@pbgc.gov (which is applicable)

 If you have a complaint about the service you have received or still need assistance after calling our 

practitioner telephone numbers listed in item 3 (1-800-736-2444 or 202-326-4242), please contact the 

Problem Resolution Officer (Practitioners):

─ Call: 1-800-736-2444, ext. 4136 or 202-326-4000, ext. 4136

─ E-mail: practitioner.pro@pbgc.gov

─ Mail or private delivery service: Send to the address for the Problem Resolution Officer posted on the 

“Contact Us for Practitioners” web page.

 For questions about our Premium Compliance Evaluation Program:

─ Call: 1-800-736-2444, ext. 6855 or 202-326-4161, ext. 6855

─ E-mail: pce@pbgc.gov

 For software developers requesting approval of XML files produced by private-sector software for use in My 

PAA, follow the submission instructions on the “Software Developer E-filing Resources for Integrating with 

PBGC” web page.

PBGC’s business hours are 8:00 am to 5:00 pm Eastern Time, Monday through Friday, except Federal Holidays.

TTY/TDD users may call the Federal relay service toll-free at 1-800-877-8339 and ask to be connected to any 

telephone number. 
Appendix 3 — Common Filing Errors

Page 62

Incorrect identifying information

The Employer Identification Number (EIN) combined with the Plan Number (PN) are used by the IRS, DOL and 

PBGC as a unique 12-digit number to identify the plan. In addition, PBGC uses the Plan’s effective date as an 

additional confirmation that the premium filing is for a plan that’s already in our database (based on previously 

reported information on Forms 5500 and on premium filings.)

Unless there has been a change to the EIN and/or PN, the EIN and plan number provided on the filing must 

match what was reported on the most recent premium filing. If there is a new EIN and/or PN, both the EIN and 

PN from the previous filing must also be reported. The EIN and PN combination may not be the EIN and PN that 

were previously used to identify a different plan. 

If we receive a filing for a plan that doesn’t indicate that it’s a New Plan and we are unable to match the plan to 

one that’s already in our database, we will be unable to perform further validations and will send an error notice

accordingly.

Sending Payment without Properly Identifying Plan

We often receive premium payments that do not contain sufficient information to identify the plan and thus, we 

cannot credit the payment to the plan’s premium account. When we receive a Comprehensive Premium Filing

indicating the amount owed, but no payment is credited to the account, we send an invoice for the premium, 

including late payment charges. This can be avoided by ensuring that the following information be included with 

all premium payments:

 EIN

 Plan number

 Plan year Commencing Date (PYC)

 My PAA Filing ID (for premium payments)

PBGC premium payments will automatically be credited to the premium account if the identifying information 

noted above is included with the payment.

The best way to avoid issues with your premium payment is to submit the payment via PBGC’s online filing 

website, My PAA (https://mypaa.pbgc.gov) or www.pay.gov and ensure you enter the correct information into 

the on-line voucher.

We continue to see much higher error rates when processing external ACH and Fedwire payments as the 

information received for each differs based on the bank which initiates the transaction.

We encourage you to review our “Premium Filing” web page each year before sending payment.
Appendix 3 — Common Filing Errors

Page 63

Lookback Rule inconsistencies (Small Plans only)

Variable-rate Premiums for Small Plans are based on UVBs for the prior plan year unless:

 The plan opted out of the Lookback Rule in 2014, or if later, the first year the plan was required to 

report Unfunded Vested Benefits.

 PBGC approved a request to opt out of the Lookback after 2014.

See “How to Determine Unfunded Vested Benefits” for details.

PBGC reviews all small plan filings to ensure that plans that didn’t opt out are, in fact, using the Lookback Rule 

and vice versa. PBGC uses the reported UVB Valuation Date to determine whether the Lookback Rule is used.

For example, if a calendar year plan reports 12/31/2023 as the UVB Valuation Date in the Comprehensive 

Premium Filing for the 2024 plan year, PBGC assumes the plan (1) has a year-end valuation date and (2) is using 

the Lookback Rule for purposes of determining its 2024 Variable-rate Premium.

 If our records indicate the plan opted out of using the Lookback Rule in an earlier year, an error letter will 

be sent.

 If our records indicate that the plan was supposed to using the Lookback rule, PBGC will review the 

discount rates reported to have been used to determine the Premium Funding Target to confirm that 

those rates are acceptable options for a plan using the Lookback Rule. If that is not the case, an error 

letter will be sent.

Similarly, if a calendar year plan reports 1/1/2024 as the UVB Valuation Date in the Comprehensive Premium 

Filing for the 2024 plan year, PBGC assumes the plan (1) has a beginning of year valuation date and (2) is not 

using the Lookback Rule for purposes of determining its 2024 Variable-rate Premium.

 If our records indicate the plan did not opt out of using the Lookback Rule in an earlier year, an error 

letter will be sent.

 If our records indicate that the plan was not supposed to use the Lookback rule, PBGC will review the 

discount rates reported to have been used to determine the Premium Funding Target to confirm that 

those rates are acceptable options for a plan that is not using the Lookback Rule. If that is not the case, 

an error letter will be sent.

See “How to Determine Unfunded Vested Benefits” section for more information.

Required explanation for certain amended filings

In most cases, if an amended filing shows a lower premium than the amount that was originally reported, you 

must provide an explanation of the specific circumstances or events that caused the change. PBGC has found 

that, in many instances, the explanation does not adequately explain the reason for the change. For example, 

“error corrected” or “premium funding target recalculated” does not suffice.

If the explanation provided is not sufficient, PBGC will contact the Plan Administrator for more details. If a 

refund was requested, this will slow down the timing of the refund significantly.
Appendix 3 — Common Filing Errors

Page 64

Reporting incorrect “Plan Year” information for final Short Plan Year

As explained in the “Short Plan Years” part of the “Who Must File” section, in some cases, plans qualify to pay a 

prorated premium for a Short Plan Year. Plans eligible for prorating report:

• The beginning and end of the Short Plan Year, 

• The number of months in the Short Plan Year, and

• The prorated premium owed.

See lines 4b and 8 on the illustrative form in the “Data to be Submitted” section. 

PBGC has found several instances where this information is inconsistent. For example, we have received filings 

that indicate the plan year begins on January 1 and ends on December 31 but also that the premium was 

prorated because there are 10 months in the Short Plan Year. Such inconsistencies may trigger unnecessary 

inquiries and/or invoices.

Reminder – Premiums are not prorated for Short Plan Years created as the result of a mid-year Merger or 

Consolidation.

Disregarding warning messages during submission process

My PAA checks for errors and inconsistencies and provides warning messages where either is found to give 

practitioners a chance to resolve the issue right away. Warning messages about the discounts rates used to 

determine the Premium Funding Target are, by far, the most prevalent, and the most frequently overlooked.

If the wrong discount rates are used to determine the Premium Funding Target, the filing will need to be 

amended and, if using the correct rates results in a higher Variable-rate Premium, late payment charges may be 

incurred.

In most cases where a discount rate warning is triggered, it is because the wrong month’s discount rates are 

used, the wrong type of rates are used (e.g., using 24-month average segments rates instead of spot segment 

rates to determine the Standard Premium Funding Target, or vice versa). With respect to small plans that use 

the Lookback Rule to determine UVBs, a common mistake is to use the discount rates that would be used if the 

plan wasn’t using the Lookback Rule (i.e., rates for the Premium Payment Year instead of for the Prior Premium 

Payment Year). 

In some cases, it turns out the correct rates were used, but a warning message is triggered because of a data 

entry/transposition error.

These errors and inconsistencies can (and should be) corrected before submitting your filing. If that doesn’t 

happen, once the filing is processed, PBGC will send an initial determination letter (IDL) to the plan 

administrator alerting them to the issue and instructing them to amend the filing to resolve the inconsistency. 

PBGC encourages practitioners to resolve these issues before the filing is submitted to avoid the IDL process 

entirely.
Appendix 4 — Special Rules for CSEC Plans 

Page 65

The appendix overrides the general instructions and provides alternate definitions for certain terms for CSEC

Plans. For CSEC Plans:

 “Standard Premium Funding Target” or “Premium Funding Target” means the present value of vested 

benefits) is determined using the plan’s funding assumptions (e.g., the plan’s selected discount rate and 

mortality table) as provided in section 306(j)(5)(C) of ERISA.

 CSEC plans cannot elect to use the Alternative Premium Funding Target instead of the Standard 

Premium Funding Target.

 UVB Valuation Date means valuation date per ERISA 306(c)(8)(b)(i) w/o regard to (b)(ii).

All other rules related to the determination of Unfunded Vested Benefits apply to CSEC Plans. This includes the 

determination of assets on the UVB Valuation Date, including whether and how to include contributions for the 

prior plan year made during the 81⁄2 month period after the plan year ends.
Appendix 5 — Paperwork Reduction Act Notice

Page 66

OMB has approved this collection of information under control number 1212-0009.

Confidentiality is that provided by the Privacy Act and the Freedom of Information Act.

PBGC estimates that preparation and submission of a premium filing takes approximately 26 minutes on average 

of in-house time and $692 on average of contracted out cost. The actual time and cost will vary depending on 

the circumstances of each plan. 

If you have comments concerning the accuracy of these burden estimates or suggestions for making the forms 

or the electronic filing process simpler, please send your comments to Pension Benefit Guaranty Corporation, at 

the address provided on PBGC’s “Contact Us” web page.