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COVID-19-Related Single-Employer Plan Sponsors and Administrators Questions and Answers

The following questions and answers provide guidance 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.

Reportable Events – Missed Contributions

As a result of the CARES Act,1 required contributions (including quarterly contributions) that would otherwise be due in 2020 are now due January 1, 2021.

Opinion Letter 90-03

Pension Benefit Guaranty Corporation 90-3 April 24, 1990 RE FERENCE: [*1] 4022 Benefits Guaranteed.>4022A> 4061 Bene fit Payments by PBGC.>29 CFR Par t 2613> OP INION: Your let ter of March 31, 1990, to Secretary of Labor Elizabet h Dole, concerning the security of pension annuitiespurc hased from insurance companies, has been referred to me for a response.

Opinion Letter 77-151

Pension Benefit Guaranty Corporation 77-151 July 21, 1977 RE FERENCE: [*1] 404 4 Allocation of Assets OP INION: Th is concerns a letter to * * * of the Pension Benefit Guaranty Corporation (the "PBGC") from * * *, apart icipant in the terminated * * * (the "Plan"). * * * requested that the PBGC determine whether it is proper for youto cha rge against Plan assets the legal fees arising from termination of the Plan. As I u nderstand the pertinent facts, on * * * you submitted a valid Notice of Intent to Terminate the Plan, and on* * * the PB GC issued a Notice of Sufficiency.

Opinion Letter 93-01

Pension Benefit Guaranty Corporation 93-1 Februa ry 16, 1993 RE FERENCE: [*1] 400 7(a) Payment of Premiums. Due Dates.29 C FR 2610 Declaration and Payment of Premiums.OP INION: I write in res ponse to your letter dated April 27, 1992, requ esting an opinion concerning the payment of premiumsby the Retirement Plan for * * * ("Pension Plan") f or the plan year commencing on March 1, 1992, under Section 4007of the Employee Retirement Income Security Act of 1974, as amended, 29 U.S.C.A. § 1307 (West 1985 & Supp.

Opinion Letter 75-31

Pension Benefit Guaranty Corporation 75-31 December 12, 1975 RE FERENCE: [*1] 404 4(a) Allocation of Assets. Requirement of Following Statutory Allocation Provisions OP INION: Th is is a confirmation of your telephone conversation with * * * of my staff on August 29, 1975. * * * of the Pension Benefit Guaranty Corporation (here inafter the "PBGC") telephoned you on July 23, 1975 , andinqui red abo ut the status of the Plan Administrator's compliance wit h our letter of June 11, 1975. The PlanAdministrator, * * * had referred us to you.

Opinion Letter 86-27

Pension Benefit Guaranty Corporation 86-27 December 17, 1986 RE FERENCE: [*1] 4041(a) Termination by Plan Administrator. Filing of Notice of Intent to Terminat404 7 Restoration of Plans OP INION: Th is is to adv ise you that t he Pension Benefit Guaranty * * * Corporation (the "PBGC") has reviewed those planswhich y ou have represented as those which X Corporat ion * * * seeks to adopt.

Opinion Letter 81-10

Pension Benefit Guaranty Corporation 81-10 May 5, 1981 RE FERENCE: 4021(a) P lans Covered. Requirements of Coverage4022 Benefits Guaranteed404 1(a) Termination by Plan Administrator. Filing of Notice of Intent to Terminate404 4 Allocation of Assets4048 Date of Termination406 2 Liability of Employer in Single Employer Plans OP INION: This is in r eference to your recent letters and teleph one conversations with * * * of my staff regarding the above-refer enced pension plan (the "Plan").

Opinion Letter 87-06

Pension Benefit Guaranty Corporation 87-6 July 15, 1987 RE FERENCE: [*1] 404 1(c)(2)(B)(iii) (SEPPAA) - Unreasonably Burdensome Pension Costs OP INION: We are writi ng to respond to your recent let ter to * * * of PBGC. In your letter, you requested that your clients bepermitt ed to participate in any proceedings befor e the Pension Benefit Guaranty Corporation ("PBGC") regarding the proposed dist ress termination of the above-referenced plan ("Plan") as of January 13, 1987 under Section404 1(c)(2)(B)(iii) of the Employee Retirement Income Security Act of 1974, as amended ("ERISA").

Opinion Letter 80-22

Pension Benefit Guaranty Corporation 80-22 December 16, 1980 RE FERENCE: 4041A Multi employer Termination404 1A(a)(2) Multiemployer Termination. Termination - Mass Withdrawal OP INION: Th is is in response to the Noti ce of Intent to Terminate filed by you on April 21, 1980, as Chairman of the Boardof Admini stration (the "Board") of the Retirement Benefit Plan * * * wi th Certain Commercial Employers (the "Plan"),a multi employer plan.

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