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# Software Developer Filing Resources for Integrating with PBGC

### Introduction

PBGC's premium filing application, My Plan Administration Account (My PAA) supports XML specifications that allow properly formatted filing data from an external source to be submitted to PBGC via My PAA. The information on this page is intended for private-sector software vendors/developers who wish to update their software to support premium filing using these XML specifications.

### Overview

                          - How Practitioners Submit Software-Prepared Filings to PBGC
                          - How Software Vendors/Developers Submit Draft Premium XML Files to PBGC for Review and Verification
                          - Vendor Listing

### PBGC Premium Filing Data Standards

                          - Premium filing XML specifications
                          - Mapping filing questions to the latest schema

### Vendor/Developer Resources

                          - Sample PBGC Premium Filings in XML Format
                          - XML Schema Validation within My PAA (Upload Step 1)
                          - Tips for Creating PBGC Premium Filings in XML Format
                          - Additional Checks PBGC Does on Submitted Filings

### Contact us

If you are a software vendor/developer and have questions or comments about how to modify your product to integrate with PBGC's requirements, please send them to the PBGC filing team at: softwareefiling@pbgc.gov

### Overview

### How Practitioners submit Software-Prepared Filings to PBGC

My PAA allows pension plan practitioners to submit premium filing information via data files that adhere to an XML specification published by PBGC in one of two ways - Import and Upload:
                          - Import : A filer imports an XML file containing filing information for a plan in their account for plan years 2014 and later. Filers then use My PAA's features to review, edit, sign and submit each filing to PBGC. Each user who works on the filing must have an account in My PAA.
                          - Upload : A filer uploads, certifies, and submits an XML file containing complete filing information for up to approximately 40 filings, for plan years 2014 and later. Only the user uploading the file is required to have an account in My PAA, the plan in their account and to be assigned the Upload Preparer role for each plan; however, filers do not have the opportunity to make changes to the filing information in My PAA using this method.

For more information about these premium filing options from the user's perspective, review the Premium Filing Options found under the Practitioners Tab, Online Premium Filing section.

### How Software Vendors/Developers Submit Draft Premium XML Files to PBGC for Review and Verification

PBGC has established a review and verification process (outlined in three steps below) for private-sector software vendors/developers to follow. The purpose of this process is to ensure that the premium XML files produced by this software adhere to the PBGC defined standards and it requires vendors/developers to submit XML files that contain filing information for a variety of filing scenarios. Note that XML files must typically be submitted to PBGC when there are changes to the schema. If the schema does not change, vendors/developers are still encouraged to validate their own sample files for the new plan year.

If the submitted XML files do not meet the standards, PBGC will provide vendors/developers with the resulting error messages and will provide any necessary assistance. If the XML files submitted by a software vendor/developer meet the standards, PBGC will assign a unique vendor identification number that must be included in all XML files created by a vendor's/developer's software.

Note: The assignment of this number simply means that the sample XML files submitted met the PBGC-defined standards. It does not mean that *all* XML files produced by a software product will be valid. For this reason, we strongly recommend that vendors/developers produce a wide variety of premium filing XML files and test them using the My PAA Upload Filing Schema Validation service. See Sample PBGC Premium Filings in XML Format for more information about the types of filings premium filing software should be able to produce.

#### To receive a vendor identification number that is valid for submission of Comprehensive Filings (for plan years starting 2021 and later), the following types of filings must be submitted to PBGC for verification:

In prior years, we allowed either PlanAdminCertification or PlanAdminCertificationExt for the Plan Admin certification, or ActuaryInformation or ActuaryInformationExt for Actuary certification. Both options will no longer be allowed, these nodes must include the “Ext” variation.  The 2014 and later XML structure will change for the following items:
                          - For “Plan Administrator Certification” (PlanAdminCertificationExt) – The Plan Admin Cert parent node is now mandatory in My PAA 2.0, in addition to the mandatory child elements:                             - PA name, email and phone number
                            - PA Sign Date is the only optional child element here 
                          - For “Enrolled Actuary Certification” (ActuaryInformationExt) - If the new Enrolled Actuary (EA) node is present within the XML, the EA name, email, phone number, Firm and Enrollment Number are now all mandatory child elements. 

### **Note: If you are already an approved vendor with a PBGC-issued Vendor ID, the PBGC only requires new test XML files for subsequent plan years if the schema changes. The last schema change was for the 2021 plan year. Vendors will continue to use the most recent Vendor ID provided in 2021 since PBGC's schema has not changed since.**

### **Form Code Node**

The Form Code is actually no longer required (still optional) for PBGC premium filings starting with the 2021 plan year, as all XSD attributes are derived from the actual plan year itself. Therefore, the PBGC is not providing a 2021 Form Code. For consistency, you can still add the applicable form code node/value for all plan years prior to 2021.

Mapping of the Form Code is unique by form type/year. You should provide the Form Code appropriate to the form type/year of the filing being submitted in the FormCode element within PremiumFiling.XSD. 

 

#### 2021 XML Test Files

Test File 1 - 2021 Comprehensive filing for a Single-employer Plan with CSEC attributes

Test File 2 - 2021 Comprehensive filing for a Single-employer plan with De minimis transferee

Test File 3 - 2021 Comprehensive filing for a Multiemployer plan, not small plan, with De minimis Transferee

Test File 4 - 2021 Comprehensive filing for a Single-employer plan, small cap, not exempt from VRP, no UVB

Test File 5 - 2020 Comprehensive filing for a Single-employer Plan, with all Risk Transfer Questions

Test File 6 - 2019 Comprehensive filing for a Multi-employer Plan, with Cessation of Coverage Explanation

Test File 7 - 2016 Comprehensive filing for a Single-employer plan, exempt from VRP, with partial Risk Transfer questions, form fields 18b(1) and 18b(2)

Test File 8 - 2014 Comprehensive filing for a Single-employer small plan that qualifies for the VRP cap and is only paying the VRP cap (i.e., is not reporting the Unfunded Vested Benefit amount)

Test File 9 - 2021 Comprehensive filing for a Single-employer plan, with De minimis Transferor

After you have validated the above nine scenarios, forward the XMLs for all of the filings described in the specific Test Files to PBGC for review (via softwareefiling@pbgc.gov), and include the following information so that each test file is clearly identified and we can call or email you if there are questions:
                          - Test file names should be descriptive and start with the requested test file number that matches the scenario described.  	 
                          - Your name, your company name, and your contact information (telephone number and email address).

### Below are the three steps for software vendors/developers to follow to send test premium filing XML files to PBGC for review:

**Step 1:** Test your XML files yourself using the My PAA Upload Filing Schema Validation service (see Testing XML files / Submission Validation Service (SVS)); and then submit them to PBGC for review. When you are ready, send an email to softwareefiling@pbgc.gov with the following information:
                          - Company name
                          - Product name
                          - Product version and/or release number
                          - Your first name and last name
                          - Business telephone number
                          - Business email address
                          - A description of the XML file that you are submitting for review that contains the plan year and type of filing (e.g., 2014 Comprehensive Filing, 2021 Comprehensive Filing).
                          - Attach the XML files that you are asking PBGC to review

**Step 2:** PBGC will acknowledge receipt of submitted XML file(s) and will verify each submission, for example, that:
                          - The XML is properly formatted
                          - Each sample file meets the approved XML schema
                          - Each file has all the required data based on the type of filing information included in that file. 

**Step 3:** PBGC will respond with XML file review results such as:
                          - If your submissions contained errors, the response will identify the files that caused the error and provide detailed error messages.
                          - If your sample files were approved, PBGC will provide you with a unique vendor identification number to insert into your final XML documents using the Provider Approval Number field. This would be a static data element and should be present in every premium filing XML submission. Note that a new vendor identification number is typically assigned when new sample files are submitted/approved as the result of a schema change.

### Vendor Listing

To date, the following private-sector software vendors/developers have supplied PBGC with sample electronic premium filings that meet PBGC's current technical requirements for an XML file for the plan years shown below. As a result, PBGC has assigned each of these vendors a vendor identification number:
                          - ASC Corporation (2014 to 2023)
                          - BLAZE SSI Corp. (2014 to 2023)
                          - DATAIR Employee Benefit Systems, Inc. (2014 to 2023)
                          - FIS - Relius Government Forms (2014 to 2023)
                          - Ftwilliam.com (2014 to 2023)
                          - Principal Financial Group (2014 to 2023)

### PBGC Premium Filing Data Standards

#### **Premium filing XML Specifications**

These data standards are applicable to premium filings starting with the 2014 plan year. A premium filing submitted to PBGC via My PAA in XML format must adhere to the premium filing XML schema published by PBGC.

A filing is composed of three core schema files (Effective 04/26/2021):

**Submission:** This primary schema defines a complete and valid premium filing. All premium filing XML files will be validated against this document. Download submission.xsd

**Submission Types:** This documents the data type definitions used throughout the schema definitions. Download submission-types.xsd

**Premium Filing:** This schema document explains the element and format definitions for 2014 and later comprehensive filing data. Download premium-filing.xsd

#### **Mapping filing questions to the latest schema**

To review additional details regarding how elements in the schemas map to data elements as identified by PBGC's forms and instructions, review the following PDF files:

2021 and later Comprehensive Filings

2021 Transfer Mapping

2021 Participant count changes

My PAA XSD to Mandatory node comparison 

### **Vendor/Developer Resources**

**Sample PBGC Premium Filings in XML Format**

**XML Samples for 2021 and later Comprehensive Filings**

To view the XML examples, open this zip file: 2021-XML-samples.zip

Reference the PDF file titled 2021-Samples-Description-Mapping.pdf for information about each filing scenario and the data used in each XML sample for Comprehensive Filings starting 2021 and later. 

### XML Schema Validation within My PAA (Upload Step 1)

The My PAA Upload Filing Schema tool validates XML files against PBGC's specifications to determine if any mandatory XML elements (nodes) were omitted. This occurs during Step 1 of the upload filing process within My PAA.

In order to access this validation tool, developers must have a My PAA account, but they will not need to have any actual plans associated with their My PAA account. Developers may login to My PAA, click the Upload Filing icon from the Home Page and select an XML file to test, then proceed to Step 1 within My PAA.  Developers can follow this process to validate XML files that contain test filing data (for plan years 2014 and forward). The schema validation tool was last updated in February 2021 to include new updates for the 2021 plan year and also to consolidate (reduce) the number of mandatory elements necessary to upload a filing to the PBGC. The schema validation tool will provide the validation outcome for each XML file you test. If an XML file passes, you will see the following on-screen message:

**No Errors. Would you like to proceed?** At this point, developers **should exit the upload process,** since this XML adheres to PBGC's schema.

If a schema error is detected, the schema validation tool will provide detailed error messages identifying the missing element. For example, if the XML did not contain the Plan Administrator's email address, which is now mandatory, the following error will display after clicking the **red plus sign (+)**:

**Error Type:** PlanAdminCertEmail

**Description: **Missing Element PlanAdminCertificationExt PlanAdmin EmailAddress

Note: Receiving a successful response from Step 1 of the My PAA upload process does not mean the premium filing does not contain other errors or inconsistencies. Uploaded filings will now be screened for the same errors, inconsistencies, and omissions as screen-prepared filings prior to submission, which occurs in Step 4 of the upload process (Filing Data Validation & Certification).

Should the screening process (Step 4) uncover any issues:
                          - You will simply make the necessary changes using your private-sector software and upload a revised XML file.
                          - Alternatively, you may import the XML file and make the changes directly on the My PAA screens.

#### Tips for Creating PBGC Premium Filings in XML Format

Please refer to the schema documents to identify all schema rules and validations (including rules governing field type and length). Following are tips and additional requirements not explicit in the schema documents that vendors/developers must follow when modifying their software to create premium filings in XML format. The information below is provided based on specific questions and issues that have been encountered by developers in generating XML files that meet the PBGC specification.

#### Additional Checks My PAA Performs on Uploaded XML Files Before Submission to PBGC

When a premium filing passes the schema, PBGC checks the following:
                          - The plan associated with the filing is in the uploaders My PAA account and they have been assigned the Upload Preparer role for each plan.  
                          - There are no in-process filings in the XML. If there is the uploader will have the opportunity to either cancel the in-process filing and continue with the upload or cancel the upload and maintain the status of the the associated in-process filings.
                          - All Business rules, calculations and certifications for the XML. If there are errors, they will be displayed and the uploader can either cancel the upload or change it to an import to correct the filing within the data screens. If there are only warning or no errors or warnings, the uploader can continue with the upload process and certify the filing(s). To help improve filing accuracy, we suggest the following:
                          - At the root level, the document defines PlanData and FilingData.
                          - Within PlanData, the date provided in PlanYearBeginDate identifies the plan year commencement date
                          - The FilingData element must contain FinalFilingData. Within FinalFilingData, the FilingPlanType element must contain either the MultiEmployer element or SingleEmployer element; this defines the plan type for a final or comprehensive filing.
                          - Additional key elements define the filing further as described below:

A Comprehensive Filing (starting plan year 2014) is defined by the presence of a Plan Year Commencement date in PlanData, PlanYearBeginDate which includes 2014 or later as the year, and the presence of the FilingData\FinalFilingData element.

My PAA will reject an XML file that has the nodes in the incorrect order. An XML file must provide the data in the specified order according to the schema. The schema enforces this rule to better enable PBGC to review and verify your sample filings. In addition, a consistent ordering of schema data elements assists with manual filing review.

Plan Contact email is now a mandatory element in the schema check, which will be the first step of the to-be upload process. 

<ns1:PlanContact>                                <st:Name xmlns:st="http://www.pbgc.gov/plan_admin/efiling/SubmissionTypes">John Doe</st:Name>                               <st:PhoneNumber xmlns:st="http://www.pbgc.gov/plan_admin/efiling/SubmissionTypes">1112223333</st:PhoneNumber>                               <st:EmailAddress xmlns:st="http://www.pbgc.gov/plan_admin/efiling/SubmissionTypes">john@doe.com</st:EmailAddress></ns1:PlanContact>

As stated above in the pre-upload submission validation check, uploaded filings will be screened for the same errors, inconsistencies, and omissions as screen-prepared filings prior to submission. This includes a comparison of My PAA calculated values versus what is being reported in the actual XML. Should the screening process uncover any issues, the XML will be updated to “Upload Error” status and the Upload Preparer will simply make the necessary changes using your private-sector software and upload a revised XML file. There are 13 different calculations which occur within My PAA as follows:

**Do not include commas in any value in a numeric XML node**.

**Do not submit an XML premium filing to the PBGC with empty XML nodes**.

My PAA will reject an XML file that has empty nodes, regardless if the nodes are mandatory or optional (the only exception to this is if the node type is "string" with no restriction for minimum length.) For example: Submitting an XML file with an empty Amended Filling node would look like this - and will generate the following error when validating the XML filing:

The http://www.pbgc.gov/plan_admin/efiling/Filing:AmendedFiling element has an invalid value according to its data type. An error occurred at, (1, 1814).

The correct way to show that a filing is not an amended filing is to submit the XML file without the node since this is an optional node.

**Be sure to use the accurate spelling of all XML nodes. In addition, the XML node names are case sensitive**.

My PAA will reject an XML file with misspelled XML node names or with node names those that do not match the case as indicated in the schema documents.

**Be sure to include correct namespace (xmlns) references to the submission, submissiontypes, and premiumfiling in your XML premium filing documents.** For example, if the following namespace is used:

xmlns:f="http://www.pbgc.gov/plan_admin/efiling/PremiumFiling" xmlns:st="http://www.pbgc.gov/plan_admin/efiling/SubmissionTypes"The tag names of XML elements should have prefixes in reference to these namespaces. Schema validation will generate an error if any of these prefixes are omitted from the XML document. For example, in the XML, "st" is the namespace prefix for Submission Types and "f" for PremiumFiling.Submitting XMLs without the "st" tag prefix may cause the following validation errors:
                          - The element  'http://www.pbgc.gov/plan_admin/efiling/Filing:SingleEmployerPremium'  has invalid child element  'http://www.pbgc.gov/plan_admin/efiling/Submission:FlatRatePremium' . Expected  'http://www.pbgc.gov/plan_admin/efiling/SubmissionTypes:FlatRatePremium' . An error occurred at, (1, 2222).
                          - The  'http://www.pbgc.gov/plan_admin/efiling/Submission:FlatRatePremium'  element is not declared. An error occurred at, (1, 2222).
                          - The  'http://www.pbgc.gov/plan_admin/efiling/Submission:TotalPremium'  element is not declared. An error occurred at, (1, 2316).

### **Including multiple filings in one XML submission**

#### PBGC developed the requirements for XML files so that multiple filings (approximately 40) can be included in one XML file in anticipation of scenarios like the following:

There is no restriction on combining different types of filings or different plan years within a single XML submission. The XML structure dictates that each filing be saved in the XML in an "envelope" - each filing would begin with the opening tag and each will end with the closing tag. One XML file may contain multiple envelopes.

It is important to note how My PAA handles an XML file that contains multiple filings for the same plan (identified by EIN/PN), depending on how the user chooses to submit the XML - either by uploading it or importing it. For example:

Third party administrators who create filings for different plans for their customers or for a sponsor who has several plans and would like to put them all in one XML file that can be imported or uploaded to My PAA at one time.

Plans that may have to submit a filing for two different plan years - e.g., the plan might need to submit an amended filing for the 2018 plan year and a new filing for the 2021 plan year.

### **Values for "Yes" and "No" nodes**

There are numerous elements within the schemas that map to checkbox items on the paper forms. In the XML, these items are represented within a parent sub-element. In some cases, depending on which node is present (Yes or No) an additional element is required, such as with Disaster Relief where a Yes node requires the Disaster Relief Explanation node. When there is not a dependent element in the selected node, a value of 'X' should be provided for the element.

July 27, 2023