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4010 Reporting

4010 Reporting

4010 Reporting Information

Background

Section 4010 of ERISA requires certain underfunded plans to report identifying, financial and actuarial information to the PBGC.  In 2016, PBGC amended its 4010 regulation.  Key changes included:

  • Codifying informal guidance provided earlier about the impact of recent legislation (MAP-21 and HATFA) on 4010 reporting,
  • Modifying  the reporting waiver for controlled groups with total underfunding of less than $15 million in all their plans so that the calculation is done without regard to the interest rate stabilization rules,
  • Adding a reporting waiver for controlled groups whose plans cover fewer than 500 participants,
  • Providing an alternative method of compliance with respect to one of the required data items (at-risk funding target).

The revised 4010 regulation is applicable for information years beginning on or after January 1, 2016 (filings due on or after April 17, 2017). Filings for earlier information years are governed by the old regulation.  

Summary of e-filing requirements

4010 information must be submitted electronically using the e-4010 module of PBGC's e-Filing Portal. The e-Filing Portal user manual provides step-by-step instructions on how to create and manage your e-Filing Portal account.

Although the e-4010 application has been updated to reflect the revised regulation, with the exception of Schedule FG1, it can also be used for most filings due in the next few months that are governed by the old regulation (e.g., a filing due 3/15/2017 for a 12/1/2015 - 11/30/2016 information year).  If you need to file Schedule FG for an information year beginning before January 1, 2016, please contact Ellen Itkin at 202-326-4000 ext. 3075 for assistance.  

1 Schedule FG is used to satisfy § 4010.6(a)(2), the regulatory provision requiring prior 4010 filers to notify PBGC the first year a 4010 filing is not required. Current 4010 filers do not need to submit Schedule FG.

If you created an e-4010 account before December, 2015, but haven't used it since 2015, please note:

  • It has been converted to an e-Filing Portal account and all of your 4010 data has been transferred to the portal.
  • You will be prompted to change your password as soon as you log in.  See Revised password requirements.

Additional information to assist in the preparation of 4010 filings follows:

  • Overview - This is a high level overview of how the e-4010 module works
  • Appendix 1 (Form) - This form is for illustrative purposes only. It presents a summary of the questions asked and the data required to be entered on the multiple screens in one easily readable, printable format.
  • Appendix 2 (Instructions) - This is a summary of the "help text" that displays on each 4010-related screen when the filer clicks the "help" button. In addition to describing how the application works, this summary provides detailed guidance on the information that must be reported.
  • Appendix 3 (Screen shots) - These illustrate what a filer sees when using the e-4010 module.

 

Assumptions

For determining Benefit Liabilities to be reported under 4010

 

Filing assistance

For assistance, contact the PBGC by sending an e-mail to ERISA.4010@pbgc.gov or by calling our toll-free practitioner number at 1-800-736-2444 extension 4070 or 202-326-4070 (DC area). TTY/ASCII users may call the federal relay service toll-free at 1-800-877-8339 and ask to be connected to the appropriate number.

Revised password requirements

This section applies only to past e-4010 account holders who haven't logged on since December 9, 2015.

On December 9, 2015, the password requirements were strengthened in accordance with federal information security regulations.  If you haven't accessed your account since then, you will need to change your password.  Please note:

  • The first time you log into the e-Filing Portal after December 9, 2015, you will be prompted to change your password. The new requirements will appear on the screen.
  • If you have a My PAA account (for preparing or submitting PBGC premium filings), you've likely already changed your My PAA password to one that meets the new criteria.  You may use that same password for the e-Filing Portal.
  • Before you will be able to change your password, you will be prompted to select the secret question you chose when you first set up your e-4010 account and then prompted to provide the answer to that question.  If you cannot remember this information, please call Ellen Itkin at 202-326-4000 ext. 3075.