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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 75-89 8-7-1975 PBGC Op Let 75-89 Coverage, Individual account plan, Termination Conversion from a covered plan to an individual account plan is a termination. 2-28-2020
Opinion Letter 75-90 10-6-1975 PBGC Op Let 75-90 Reportable events Transfer of plan assets to another plans is a reportable event. 2-28-2020
Opinion Letter 75-91 7-15-1975 PBGC Op Let 75-91 Benefit reduction, Reportable events A reduction in benefits is not considered a plan termination but is a reportable event. 2-28-2020
Opinion Letter 76-103 8-23-1976 PBGC Op Let 76-103 Benefit guarantee, Death benefits PBGC’s position on guaranty of death benefit. 2-28-2020
Opinion Letter 76-106 9-3-1976 PBGC Op Let 76-106 Coverage, Professional service employer plan Physician-secretary is a Professional Service Employer plan exempt from Title IV coverage. 2-28-2020
Opinion Letter 76-107 9-7-1975 PBGC Op Let 76-107 Termination, Allocation of assets Allocation of assets of terminating plan otherwise than in accordance with section 4044 is not allowed. Transfer of asset to a defined contribution plan requires that all participants be offered option for immediate receipt of their benefits. 2-28-2020
Opinion Letter 76-109 9-14-1976 PBGC Op Let 76-109 Coverage A trust under a plan must be "created or organized" in the "United States" and be "maintained at all times as a 2-28-2020
Opinion Letter 76-11 1-20-1976 PBGC Op Let 76-11 Reportable events Transfer of plan assets to another plan does not require PBGC approval, but it is a reportable event requiring notification. 2-28-2020
Opinion Letter 76-111 9-16-1976 PBGC Op Let 76-111 Employer liability Asset purchaser assuming some plans was not a successor corporation for plans that it did not assume. 2-28-2020
Opinion Letter 76-112 9-28-1976 PBGC Op Let 76-112 Benefit guarantee A participant who has completed the requisite number of years of service and has attained retirement age has a nonforfeitable vested benefit in the plan, even if he has not ended his employment as the time of plan termination. 2-28-2020
Opinion Letter 76-114 10-1-1976 PBGC Op Let 76-114 Reportable events Elimination of a death benefit is a reportable event. 2-28-2020
Opinion Letter 76-117 11-3-1976 PBGC Op Let 76-117 Termination No plan termination occurred when subsidiaries ended plan participation. 2-28-2020
Opinion Letter 76-118 11-8-1976 PBGC Op Let 76-118 Coverage, tax qualification Once a plan is determined to be qualified by IRS, it is qualified for purposes of Title IV until qualification is revoked. 2-28-2020
Opinion Letter 76-119 11-15-1976 PBGC Op Let 76-119 Residual assets Because plan does not provide for reversion of excess assets to sponsor, residual assets must be distributed to plan participants and their beneficiaries, pro rata, in relation to their accrued benefits. 2-28-2020
Opinion Letter 76-12 1-27-1976 PBGC Op Let 76-12 Individual account plan Amendment of a plan from a defined benefit plans to an individual account plan results in the plan’s termination. 2-28-2020
Opinion Letter 76-121 12-22-1976 PBGC Op Let 76-121 Reportable events The reduction in the number of plan participants is a reportable event. 2-28-2020
Opinion Letter 76-17 2-5-1976 PBGC Op Let 76-17 Benefit guarantee Discusses benefit guaranty and its limits for a retiree receiving monthly benefits from an ongoing plan. 2-28-2020
Opinion Letter 76-24 2-14-1976 PBGC Op Let 76-24 Merger, Reportable events PBGC approval is not needed to merge a single employer plan into a multiemployer plan, but such a transaction would be a reportable event. 2-28-2020
Opinion Letter 76-28 2-24-1976 PBGC Op Let 76-28 Coverage Advises that defined contribution plans which defined benefit features may be subject to coverage. 2-28-2020
Opinion Letter 76-03 1-8-1976 PBGC Op Let 76-3 Termination, Allocation of assets Plan administrator must allocate assets to participant receiving early retirement benefits and may not allocate assets to participants whose benefit claims had been fully satisfied prior to termination of plan. 2-28-2020
Opinion Letter 76-31 3-3-1976 PBGC Op Let 76-31 Allocation of assets, Benefit guarantee Section 4044 asset allocation rules take precedence over any contrary plan provisions. 2-28-2020
Opinion Letter 76-33 3-5-1976 PBGC Op Let 76-33 Reportable events Plan merger constitutes a reportable event. 2-28-2020
Opinion Letter 76-34 3-8-1976 PBGC Op Let 76-34 Termination, Voluntary plan termination Involuntary termination requirements in section 4042(a) do not apply to voluntary terminations under section 4041. 2-28-2020
Opinion Letter 76-37 3-15-1976 PBGC Op Let 76-37 Benefit guarantee Discusses how the five-year phase-in rule impacts guarantee of certain recent benefit increases and that certain early retirement supplements are not guaranteed. 2-28-2020
Opinion Letter 76-40 3-19-1976 PBGC Op Let 76-40 One plan Discusses four plans in one plan document with one trust. Sale of a unit and separation of the unit’s assets from the master trust is not a reportable event, nor a termination of one of the plans. 2-28-2020