Reportable events

Answers questions related to plan sponsor obligations and PBGC operations in light of the Coronavirus Aid, Relief, and Economic Security (CARES) Act and the COVID-19 pandemic.

Guidance on compliance with the active participant reduction event requirements of section 4043(c)(3) of ERISA and PBGC’s regulation on Reportable Events and Certain Other Notification Requirements (29 CFR part 4043.23(a)). PBGC adopted a rule addressing the issue effective 3/5/2020. (See 29 CFR part 4010.)

Transfer of plan assets to another plan does not require PBGC approval, but it is a reportable event requiring notification.

Change in funding method does not constitute a reportable event.

Transfer of plan assets to another plans is a reportable event.

The reduction in the number of plan participants is a reportable event.

Elimination of a death benefit is a reportable event.

The sale by a parent corporation with a division that maintains a pension plan with nonforfeitable benefits which are not funded of $1 million or more of an incorporated subsidiary, irrespective of its relative size, results in a reportable event.

A reportable event takes place with the merger of a single employer plan into a multiemployer plan.

The described spin-off is a reportable event and sales transaction principles apply to the spin-off and transfer transactions.