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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.

Amended 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. Indicate whether you want the overpayment refunded or applied to the next year‘s premium for the plan.
  • If you request that an overpayment be applied to the next year‘s premium, you should claim the amount of the overpayment as a credit on the next year‘s premium filing for the plan. If you want a refund by electronic funds transfer, provide the necessary information; we will make the transfer through the automated clearing house (ACH) system. A request for a refund must be made within the period specified in the applicable statute of limitations (generally six years after the overpayment was made).

    If there are unpaid premiums, interest, or penalties for your plan for prior years, you may request PBGC to apply all or part of an overpayment toward payment of those unpaid prior year amounts. Such a request should be made in writing (e-mail, letter or fax-see Appendix 2). Note that an overpayment for one plan cannot be applied to offset an underpayment on another plan.

    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.)

    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 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 at www.pbgc.gov.

    Refunds
    If we determine that a requested refund is in order, we will send the plan administrator a letter confirming that the refund will be forthcoming. This letter will include an account history describing how the overpayment was used to satisfy any outstanding premium, interest, or penalty amounts. The refund will subsequently be issued by the U.S. Treasury. You should receive the refund typically within 60 days after you receive the PBGC refund letter. Please be aware that refunds will take longer to process during peak filing periods, which begin in February and October.

    PBGC may apply all or a portion of an overpayment to the satisfaction of outstanding premium, penalty and interest charges. Overpayments are refunded only if there are funds remaining after outstanding premium, penalty and interest charges are satisfied.

    Reconciling Estimates
    For Large and Mid-size 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 - Comprehensive Filing" section for additional information on how to reconcile an estimated Variable-rate Premium.

    For Large Plans, the Flat-rate Premium reconciliation filing is due on the same date the comprehensive premium filing is due. The comprehensive premium filing is designed to enable you to reconcile an estimate Flat-rate Premium and report the other premium information (Variable-rate Premium data, miscellaneous data, etc.) as part of the same filing.

    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.