Asset reversion

PBGC’s position requiring distribution of assets as soon as practicable after PBGC’s 60-day review does not apply to surplus assets when there is a dispute concerning distribution.

A split-up of one plan and the termination of another is not subject to the asset reversion implementation guidelines; PBGC recognizes the termination and reestablishment of a plan.

Implementation guidelines do not generally apply to a transfer of assets from a single-employer plan to a multiemployer plan, followed by the termination of the single-employer plan, but because plan termination is a prerequisite to a reversion of plan assets to an employer, PBGC will not recognize a plan termination when it is intended as a means to recover surplus plan assets without satisfying termination requirements.