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Technical Update 96-4: Filing Extension for Reporting the Value of Benefit Liabilities

Technical Update Number:

The Retirement Protection Act of 1994 added Section 4010 to ERISA. Section 4010 requires controlled groups maintaining plans with large amounts of underfunding to submit financial and actuarial information annually to the Pension Benefit Guaranty Corporation.

On December 20, 1995, the PBGC published a final rule setting out the information required under Section 4010 (29 CFR Part 2628, 60 Fed. Reg. 66054). On March 15, 1996, the PBGC published Technical Update 96-3 addressing questions that the PBGC had received about the regulation.

A number of companies required to report on April 15, 1996 have requested additional time in which to submit the value of their plans' benefit liabilities (under section 2628.8(a)(2) of the regulations). They point out that this is the first year for the annual reporting requirement and that they did not routinely calculate the value of benefit liabilities prior to publication of the regulation.

To address these problems, PBGC is hereby granting an automatic extension for reporting the value of benefit liabilities until May 31, 1996, for all filers whose reports are due before that date. The extension is conditioned on submission of the actuarial valuation report prepared for purposes of financial disclosure under the Statement of Financial Accounting Standards No. 87 by the original due date (April 15 for calendar-year filers), along with the other information required by the regulation.

This extension applies to all reports due before May 31, 1996, whether or not an extension was requested. Requests for extension by filers with later due dates should be made at least 15 days before the due date.