As described in further detail below, absent Congressional action, plan sponsors should take note that PBGC premium filings will generally be due one month earlier than usual for plan years beginning in 2025. This modification only applies for 2025.

Under ERISA Section 4007, the PBGC determines when premium filings—the submission of required data and payment

Employers may be bound by multiemployer pension plans’ trust agreements and collections policies, but the force of these governing documents may have its limits. In Nevada Resorts Ass’n–Int’l All. of Theatrical Stage Emps. and Moving Picture Mach. Operators of the U.S. and Canada Local 720 Pension Trust v. JB Viva Vegas, L.P., No. 2:19-cv-00499

ERISA Section 4010 requires a contributing sponsor of certain single-employer pension plans, as well as the sponsor’s controlled group members, to provide controlled group, financial, and actuarial information to the PBGC each year.  The requirement generally applies when one or more plans within a controlled group has a funding target attainment percentage for 4010 purposes

As previously discussed, the Pension Benefit Guaranty Corporation (the “PBGC”) issued final regulations in July 2022 for plans that receive special financial assistance (“SFA”) under the American Rescue Plan Act of 2021 (“ARPA”).  Among other things, the regulations imposed special withdrawal liability rules on plans that receive SFA – including a phase-in period for