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Guidance Document Database

The documents listed below are PBGC’s guidance documents. The contents of these documents do not have the force and effect of law, unless expressly authorized by statute or incorporated into a contract, and are not meant to bind the public in any way. These documents are intended only to provide clarity to the public regarding existing requirements under the law or agency policies.

If you would like to request the withdrawal or modification of an existing guidance document, please submit your request, including your contact information, to the General Counsel at or at Regulatory Affairs Division, Pension Benefit Guaranty Corporation, Office of the General Counsel, 1200 K Street NW, Washington, DC 20005–4026.

Title Issuance Date Agency Identifiersort descending Topics Summary Posted Date
Opinion Letter 75-20 1-24-1975 PBGC Op Let 75-20 Coverage, Professional service employer plan Licensed veterinarians are “licensed practitioners of the healing arts” for purposes of the Professional Service Employer plan exemption. 2-28-2020
Opinion Letter 75-21 1-24-1975 PBGC Op Let 75-21 Benefits, plan document PBGC will look to the terms of the plan documents in determining whether a benefit is nonforfeitable. 2-28-2020
Opinion Letter 75-23 3-11-1975 PBGC Op Let 75-23 Benefit guarantee Addresses ambiguities and how PBGC will resolve them in the application of the phase-in of guaranteed benefits. 2-28-2020
Opinion Letter 75-31 12-12-1975 PBGC Op Let 75-31 Allocation of assets, Termination A proposed plan distribution must be in compliance with § 4044 regardless of whether the IRS has issued a determination letter regarding a plan termination. IRS cannot issue an exception to section 4044. 2-28-2020
Opinion Letter 75-32 12-31-1975 PBGC Op Let 75-32 Plan assets, Allocation of assets Assets intended to fund insurance company annuities, but which are retained by the plan are subject to allocation procedures. 2-28-2020
Opinion Letter 75-39 10-8-1975 PBGC Op Let 75-39 Coverage, Substantial owners plan A plan maintained exclusively for substantial owners is exempt from coverage under Title IV. 2-28-2020
Opinion Letter 75-04 3-20-1975 PBGC Op Let 75-4 Coverage, Individual account plan Plan is not an Individual account plan and is not exempt from coverage under Title IV. 2-28-2020
Opinion Letter 75-40 8-12-1975 PBGC Op Let 75-40 Coverage, Welfare plans Welfare plans are not covered under Title IV. 2-28-2020
Opinion Letter 75-41 5-13-1975 PBGC Op Let 75-41 Coverage, Governmental plan To be excluded from coverage, all employees covered by the plan must be public employees and the political subdivision must be the plan sponsor. 2-28-2020
Opinion Letter 75-42 7-2-1975 PBGC Op Let 75-42 Coverage, Nonresident aliens Canadian participants are covered. 2-28-2020
Opinion Letter 75-43 6-25-1975 PBGC Op Let 75-43 Coverage, Substantial owners plan A plan with one participant who is a substantial owner is not covered. 2-28-2020
Opinion Letter 75-44 12-8-1975 PBGC Op Let 75-44 Coverage, Governmental plan, “Established and maintained” A plan maintained by a public agency or political subdivision which has been taken over from a private business is excluded from coverage. 2-28-2020
Opinion Letter 75-54 6-23-1975 PBGC Op Let 75-45 Coverage Title IV does not cover deposits made into a Keogh Trust. 2-28-2020
Opinion Letter 75-45 6-30-1975 PBGC Op Let 75-45 Coverage, Governmental plan Plan of transit system acquired by county is excluded from coverage. 2-28-2020
Opinion Letter 75-46 9-23-1975 PBGC Op Let 75-46 Coverage, Governmental plan A plan sponsored by a political subdivision that has taxing power is excluded from coverage. 2-28-2020
Opinion Letter 75-48 11-19-1975 PBGC Op Let 75-48 Coverage, Premiums Fully insured plans are required to pay premiums. 2-28-2020
Opinion Letter 75-49 11-10-1975 PBGC Op Let 75-49 Coverage, Professional service employer plan A plan maintained by an actuary with the principal business the performance of actuarial services is a professional service employer plan. 2-28-2020
Opinion Letter 75-05 4-24-1975 PBGC Op Let 75-5 Individual account plan Individual account plan is exempt from coverage under Title IV. 2-28-2020
Opinion Letter 75-53 12-4-1975 PBGC Op Let 75-53 Coverage, Nonresident aliens Plan is governed by laws of Virgin Islands. Plan is not a qualified plan and is exempt from coverage under Title IV. 2-28-2020
Opinion Letter 75-55 11-10-1975 PBGC Op Let 75-55 Coverage, plan document A plan without a written plan document is not a qualified plan and is excluded from coverage. 2-28-2020
Opinion Letter 75-58 10-3-1975 PBGC Op Let 75-58 Coverage The fact that a benefit formula may be modified by a plan amendment does not alter the defined benefit nature of the plan.  If the plan is amended to convert it to an individual account plan, it would be treated as terminated. 2-28-2020
Opinion Letter 75-06 1-21-1975 PBGC Op Let 75-6 Plan year A plan year is the fiscal year on which the records of a plan are kept. 2-28-2020
Opinion Letter 75-07 5-8-1975 PBGC Op Let 75-7 Merger, Reportable events A reportable event takes place with the merger of a single employer plan into a multiemployer plan. 2-28-2020
Opinion Letter 75-78 12-3-1975 PBGC Op Let 75-78 Premiums A plan that established itself and had its first plan year end on the same day must pay partial premiums for that plan year. 2-28-2020
Opinion Letter 75-85 9-11-1975 PBGC Op Let 75-85 Defined benefit plan A plan where participants are eligible for benefits as calculated from time to time by an actuary is a defined benefit plan providing basic benefits. 2-28-2020