Signing and Uplading PBGC Filings
A question has been raised about the Plan Administrator’s and/or Actuary’s certification when the PBGC Premium forms are uploaded to the PBGC. Per Diane Morstein of the PBGC, the premium forms need not be signed before the Upload takes place, however, paper forms must be printed and signed by the Plan Administrator and, if necessary, by the actuary. Also, under the Certification Rules which are available on the upload screen in My PAA in the Certification of Filing section, states "If the person who uploads is not the plan administrator or enrolled actuary, the uploader will typically print out copies of the uploaded information and send one copy to the plan administrator and one copy to the enrolled actuary (if an enrolled actuary must certify) for certification. Certified copies of filing information are subject to audit and must be retained with plan records for six years from the due date of the filing."
For example:
TPA company sends the premium forms to their outside actuary who reviews the forms, completes the Schedule A, prints the forms, uploads the forms to the PBGC and then forwards the printed forms (with his/her signature, if necessary) with the check voucher back to TPA company. TPA company then forwards the forms to the Plan Administrator for signature and retention along with the check voucher and instructions for premium payment.
The Valuation Specialist of Full Admin Company prepares all premium filing forms in private software, prints them and gives them to the in-house actuary for review and approval. The in-house actuary reviews the forms, indicates any changes he wants and returns the forms to the Valuation Specialist for correction/completion, uploading and mailing to the client. The Valuation Specialist makes any changes, uploads the filing, gets the actuary’s signature on the paper forms and forwards those forms to the Plan Administrator for signature and retention with the check voucher printed during the Upload process.
Those who are concerned about liability because of the upload occurring before the actual signing takes place, have the option to fax or email the forms to the Plan Administrator for review and signature and only uploading after the signed copy has been returned to you. This is not a PBGC requirement. An Uploaded filing is not a complete filing until the premium has been paid. The premium payment is the Plan Administrator’s approval of the filing.
One also has the option of going thru the longer, more involved Import process in My PAA.
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Article DKB00190