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Practitioners

Correcting Filings and Reconciling Estimates

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 in My PAA for identifying your payment so that we can associate it with your information filing.

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.

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. In this case, 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. To do so, 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 (EFT), provide the necessary information in the applicable section of the amended filing; we will make the transfer through the ACH system or Fedwire (Fedwire transfers are available only for refunds of $100,000 or greater). For Fedwire funds transfers, you can have the refund credited to a sub-account within the main account if you provide the sub-account number to us.

    With either option, the overpayment will appear as a "credit" 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 in the "Premium Payment Instructions and Addresses" section of the Practitioners Page at www.pbgc.gov.

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).

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.