E-Filing Portal Replaces e-4010 Application
On December 9, 2015 PBGC made some changes to its e-4010 application. Below is a summary of the changes.
- Required password change - The password requirements have been strengthened in accordance with federal information security regulations. Please note:
- If you have a My PAA account (for preparing or submitting PBGC premium filings), you've already changed your My PAA password to one that meets the new criteria. You may use that same password for the new e-filing portal.
- The first time you log into the e-4010 application after December 9, 2015, you will be prompted to change your password. The new requirements will appear on the screen.
- Before you will be able to change your password, you will be prompted to select the secret question you chose when you first set up your e-4010 account and then prompted to provide the answer to that question. If you cannot remember this information, please call Ellen Itkin at 202-326-4000 ext. 3075.
- If you expect to be working on a 4010 report in early 2016, we encourage you to change your password well before the due date, just in case you need assistance.
- New e-filing portal with other applications - PBGC recently launched a new e-filing portal from which multiple e-filing applications are available. Your e-4010 account has been converted to an e-filing portal account. All of your e-4010 information has carried over to your new e-filing portal account (e.g., previously submitted filings, filings still in draft form, actuaries assigned to a particular filing). Despite the new name, we don't expect you will notice any differences. Please note:
- Nothing has changed with respect to how you log in to your account. You can still use whatever method you used in the past (e.g., bookmarked URL, clicking on link on PBGC's 4010 webpage, etc.)
- In addition to being able to prepare and submit 4010 filings via the e-filing portal, you will also have the option of using your account to file information required under PBGC's new ERISA 4043 regulation (i.e., reportable events)li including Form 200 (for reporting missed contributions in excess of $1 million).
- The new e-filing portal also has a multiemployer plan module from which various applications and notices may (or in some cases, must) be submitted to PBGC (e.g., applications for financial assistance, annual funding notices, critical and endangered notices).
- My PAA is not accessible via the new e-filing portal.
Click here to access a user manual with step-by-step instructions on how to create and manage your e-Filing Portal account.
4010 Reporting Information
Section 4010 of ERISA requires certain underfunded plans to report identifying, financial and actuarial information to the PBGC. 4010 information must be submitted electronically. 4010 regulations are at 29 CFR Part 4010.
On March 23, 2016, PBGC published a final rule amending the 4010 regulation. Key changes include:
- Codifying the guidance provided in Technical Updates 12-2 and 14-2 regarding the impact of recent legislation (MAP-21 and HATFA) on 4010 reporting,
- Modifying the existing reporting waiver for controlled groups with total underfunding of less than $15 million in all their plans so that the calculation is done without regard to the interest rate stabilization rules,
- Adding a reporting waiver for controlled groups whose plans cover fewer than 500 participants, and
- Providing an alternative method of compliance with respect to one of the required data items (at-risk funding target).
The new 4010 regulation applicable for information years beginning on or after January 1, 2016 (filings due on or after April 17, 2017). Filings for earlier information years are governed by the old regulation.
The e-4010 application has not yet been updated to reflect the new regulation. The application will be updated and ready to accept 4010 filings for information years beginning on or after January 1, 2016, by the end of 2016. If you would like to be notified when the update occurs, sign up for PBGCs’ subscription service on the “what’s new” webpage.
Summary of e-filing requirements
The following requirements apply to filings subject to the old regulation (i.e., filings for information years beginning before January 1, 2016). PBGC will post similar information for filings subject to the new regulation before the end of 2016.
- Overview - This is a high level overview of how the application works.
- Appendix 1 (Form) - This form is for illustrative purposes only. It presents a summary of the questions asked and the data required to be entered on the multiple screens in one easily readable, printable format.
- Appendix 2 (Instructions) - This is a summary of the "help text" that displays on each screen when the filer clicks a button to indicate the need for assistance. In addition to describing how to use the web-based application, this summary provides detailed guidance on the information that must be reported under the final 4010 regulations.
- Appendix 3 (Screen shots) - These illustrate what a filer sees when using the web-based application.
Technical Updates on 4010 filings
- Technical Update 14-2: Effect of HATFA on 4010 Reporting. (October 17, 2014)
- Technical Update 12-2: Effect of MAP-21 on 4010 Reporting. (September 11, 2012)
- Technical Update 09-2: ERISA section 4010 reporting; Alternative form-of-payment assumption for determining benefit liabilities. (March 25, 2009)
- Technical Update 07-2: Funding-Related Determinations for Reporting Under Parts 4010 and 4043; Effect of the Pension Protection Act of 2006; Transitional Guidance. (December 15, 2007)
- Technical Update 07-1: Effect of Treasury Mortality Tables on PBGC Requirements. (February 13, 2007)
- Technical Update 96-3: Annual Financial and Actuarial Information Reporting (March 15, 1996)
|Note about Technical Update 96-3:|
|Since the time this technical update was published, the 4010 regulation has been amended, so some of the guidance provided in this Technical Update no longer applies. Specifically, the reference to optional assumptions in Q&A 12 is invalid for information years ending on or after December 31, 2005.|
Enrolled Actuaries Meeting Bluebooks - 4010 filing requirements
In preparation for previous Enrolled Actuaries Meetings, staff of the Pension Benefit Guaranty Corporation met with representatives of the Enrolled Actuaries Program Committee to discuss a number of questions. Summaries of the questions and answers (in PDF format) discussed at the meetings are available here as a public service.
The summaries reflect the views of individual staff members and do not represent the official position of PBGC.
- 2012 Question and Answer Summary (Questions 17-18) [PDF]
- 2011 Question and Answer Summary (Question 14) [PDF]
- 2010 Question and Answer Summary (Questions 21-22) [PDF]
- 2009 Question and Answer Summary (Questions 21-24) [PDF]
- 2007 Question and Answer Summary (Questions 3, 17, 18) [PDF]
- 2006 Question and Answer Summary (Questions 16-20) [PDF]
- 2004 Question & Answer Summary (Questions 14 -18) [PDF]
- 2003 Question & Answer Summary (Questions 15, 18, and 19) [PDF]
- 2002 Question & Answer Summary (Questions 19-21) [PDF]
- 2001 Question & Answer Summary (Question 17) [PDF]
- 2000 Question & Answer Summary (Question 21 - 25) [PDF]
- 1998 Question & Answer Summary (Question 34) [PDF]
For assistance, contact the PBGC by sending an e-mail to ERISA.firstname.lastname@example.org or by calling our toll-free practitioner number at 1-800-736-2444 extension 4070 or 202-326-4070 (DC area). TTY/ASCII users may call the federal relay service toll-free at 1-800-877-8339 and ask to be connected to the appropriate number.