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Guidance Document Database

The documents listed below are PBGC’s guidance documents, as defined by EO 13891, sec. 2(b), see Federal Register Notice. 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. PBGC will only cite, use, or rely on any guidance that is not posted in this database to establish historical facts.

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 GuidanceComments@pbgc.gov or at Regulatory Affairs Division, Pension Benefit Guaranty Corporation, Office of the General Counsel, 1200 K Street NW, Washington, DC 20005–4026. For additional information, see PBGC’s procedures for guidance documents.

Title Issuance Date Agency Identifiersort descending Topics Summary Posted Date
Opinion Letter 74-23 12-18-1974 PBGC Op Let 74-23 Coverage A plan maintained by a union and funded only by contributions from union members is not covered under Title IV 2-28-2020
Opinion Letter 74-24 12-12-1974 PBGC Op Let 74-24 Coverage A plan maintained by a union and funded only by contributions from union members is not covered under Title IV 2-28-2020
Opinion Letter 74-25 11-8-1974 PBGC Op Let 74-25 Coverage, Nonresident aliens Plan of Canadian company with mostly Canadian participants is not covered under Title IV. 2-28-2020
Opinion Letter 74-26 11-14-1974 PBGC Op Let 74-26 Coverage, Professional service employer plan Company owners are physicians and company provides medical services. Plan is exempt as a Professional Servicer Employer plan. 2-28-2020
Opinion Letter 74-27 12-13-1974 PBGC Op Let 74-27 Coverage, Professional service employer plan PBGC could not determine that an employer engaged in services different than those specified in 4021(c) was a professional service employer. 2-28-2020
Opinion Letter 74-28 12-6-1974 PBGC Op Let 74-28 Benefit guarantee PBGC’s plan termination insurance program covers retirees in pay status. 2-28-2020
Opinion Letter 74-03 11-14-1974 PBGC Op Let 74-3 Coverage, Individual account plan Title IV excludes a defined benefit plan to the extent it is treated as an Individual account plan under 1002(35)(B). 2-28-2020
Opinion Letter 74-05 11-8-1974 PBGC Op Let 74-5 Coverage, Individual account plan Profit sharing plan is an Individual account plan which is exempt from coverage under Title IV. 2-28-2020
Opinion Letter 74-06 11-14-1974 PBGC Op Let 74-6 Coverage, Nonresident aliens Plan is not exempt from coverage under Title IV because of Canadian participants. 2-28-2020
Opinion Letter 74-08 12-23-1974 PBGC Op Let 74-8 Premiums, tax qualification A plan is covered for purposes of premium payments on the later of the date of establishment or the effective date. 2-28-2020
Opinion Letter 75-10 4-8-1975 PBGC Op Let 75-10 Coverage, Individual account plan Individual account plan exemption from coverage. 2-28-2020
Opinion Letter 75-104 7-8-1975 PBGC Op Let 75-104 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 75-106 11-14-1975 PBGC Op Let 75-106 Coverage, Individual account plan Plan is not an Individual account plan because it does not provide for individual accounts for each participant. Plan is covered under Title IV. 2-28-2020
Opinion Letter 75-107 11-21-1975 PBGC Op Let 75-107 Coverage, Professional service employer plan Pharmacist is a professional individual for purposes of the Professional Service Employer plan exemption. 2-28-2020
Opinion Letter 75-108 5-14-1975 PBGC Op Let 75-108 Coverage, Individual account plan Individual account plan is exempt from coverage. 2-28-2020
Opinion Letter 75-11 1-14-1975 PBGC Op Let 75-11 Interest, Penalties PBGC is not authorized to waive interest charges on late premium payments. 2-28-2020
Opinion Letter 75-110 7-15-1975 PBGC Op Let 75-110 Coverage, Individual account plan Individual account plan is exempt from coverage. 2-28-2020
Opinion Letter 75-113 12-3-1975 PBGC Op Let 75-113 Coverage Plan continues to be covered under Title IV because IRS has not determined the plan is disqualified. 2-28-2020
Opinion Letter 75-115 5-30-1975 PBGC Op Let 75-115 Termination, Reportable events Discusses that change of insurance carrier is not a termination nor a reportable event 2-28-2020
Opinion Letter 75-116 12-31-1975 PBGC Op Let 75-116 Termination, Withdrawal Discusses the difference between a multiemployer plan and a multiple employer plan and the termination provisions applicable to the latter. 2-28-2020
Opinion Letter 75-13 1-6-1975 PBGC Op Let 75-13 Coverage, Individual account plan Individual account plan is exempt from coverage 2-28-2020
Opinion Letter 75-15 1-24-1975 PBGC Op Let 75-15 Coverage, defined contribution plans Defined contribution plans are not covered plans under Title IV. 2-28-2020
Opinion Letter 75-17 11-14-1975 PBGC Op Let 75-17 Coverage, Individual account plan Addresses the individual account plan coverage exemption. 2-28-2020
Opinion Letter 75-19 1-9-1975 PBGC Op Let 75-19 Coverage, Professional service employer plan, Substantial owners plan Addresses the Professional Service Employer plan and Substantial Owner plan coverage exemptions. 2-28-2020
Opinion Letter 75-2 4-4-1975 PBGC Op Let 75-2 Coverage, Individual account plan Individual account plan is exempt from coverage under Title IV. 2-28-2020

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