SFA Filing Instruc General Instructions for Multiemployer Plans Applying fo

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1212-0074 Expires 01/31/2023

MULTIEMPLOYER PROGRAM DIVISION
GENERAL INSTRUCTIONS FOR MULTIEMPLOYER PLANS APPLYING FOR
SPECIAL FINANCIAL ASSISTANCE

General Information
These general instructions are guidance setting forth the requirements for a multiemployer
plan filing an application for special financial assistance (SFA) with PBGC. This guidance
refers to section 4262 of the Employee Retirement Income Security Act of 1974 (ERISA)
and PBGC’s SFA regulation (29 CFR part 4262).
Section 9704 of the American Rescue Plan (ARP) Act of 2021 (P.L. 117-2) added section
4262 to ERISA, which authorizes PBGC to provide SFA to eligible multiemployer plans.
Certain multiemployer plans are eligible to apply for SFA if they are in critical and
declining or critical status; were approved to suspend benefits under the Multiemployer
Pension Reform Act of 2014 as of March 11, 2021; or became insolvent after December 16,
2014, and have remained insolvent and have not terminated as of March 11, 2021.
On July 8, 2022, PBGC published a final rule that made changes to PBGC’s SFA regulation
and replaced an interim final rule issued on July 9, 2021. The final rule is effective on
August 8, 2022.
The SFA regulation sets forth the requirements for SFA applications and related restrictions
and conditions. These general instructions, along with the corresponding templates,
addendums, and SFA assumptions guidance, provide additional guidance to multiemployer
plans on how to prepare and file the required SFA application information.
The amount of SFA requested is determined as of the plan’s “SFA measurement date.”
Except for a plan that filed its initial SFA application before August 8, 2022, when the
interim final rule was in effect, a plan’s SFA measurement date is defined in § 4262.2 of
PBGC’s SFA regulation as the last day of the third calendar month immediately preceding
the date the plan’s initial application is filed. For example, if the plan’s initial application
was filed on March 15, 2023, its SFA measurement date would be December 31, 2022; if
the plan’s application was filed on July 1, 2023, its SFA measurement date would be April
30, 2023. For a plan that submitted its initial SFA application under the interim final rule
before August 8, 2022, its SFA measurement date is the last day of the calendar quarter
immediately preceding the date the plan’s initial application was filed.
Addendum A provides instructions on the additional information required for a plan that
engaged in certain events between July 9, 2021, and its “SFA measurement date.”
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Addendum B provides instructions for the notice of reinstatement of benefits required to be
issued by a plan sponsor of a plan that suspended benefits.
Addendum C provides instructions for filing a supplemented application for plans that
received payment of SFA under the terms of the interim final rule and seek (1) to apply for
additional SFA or (2) subject themselves, without applying for additional SFA, to the
conditions of the final rule.
Addendum D provides instructions on additional information to be filed for MPRA plans
(MPRA plans are defined in § 4262.4(a)(3) of PBGC’s SFA regulation).
Pre-application consultations and questions
A plan sponsor may request an informal pre-application consultation to discuss a plan’s
potential application for SFA. At a pre-application consultation, PBGC staff members
cannot offer binding decisions on such topics as a plan’s eligibility for SFA or the amount of
SFA to which it might be entitled. However, staff members can provide overviews of the
SFA program and the application process and offer helpful tips. To request a pre-application
consultation, send an email to the Multiemployer Program Division mailbox at
[email protected], with the subject “Special Financial Assistance
Consultation Request from (Plan Name).” You may send other questions about the SFA
program to this email address as well, with the subject “Special Financial Assistance
Question from (Plan Name).”

Filing an Application for Special Financial Assistance
Where to file an application
An application, with the exception of a lock-in application, must be submitted to PBGC
electronically through PBGC’s e-Filing Portal, (https://efilingportal.pbgc.gov/site/). After
logging into the e-Filing Portal, go to the Multiemployer Events section and click “Create New
ME Filing.” Under “Select a filing type,” select “Application for Financial Assistance –
Special.” Note: revised and supplemented applications must be submitted by selecting “Create
New ME Filing.”
A lock-in application under § 4262.10(g) is treated as a plan’s initial application and locks in the
plan’s SFA measurement date, participant census data, non-SFA interest rate, and SFA interest
rate. It is submitted by email to [email protected] in accordance with the lockin application instructions.
Note: In the case of a plan applying for priority consideration, PBGC will transmit the
plan’s application to the U.S. Department of the Treasury (Treasury Department). See
section 432(k)(1)(D) of the Internal Revenue Code and guidance issued by the Treasury
Department and Internal Revenue Service (IRS) (Notice 2021-38) for further information.

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When to file an application
An initial application must be filed no later than December 31, 2025, and a revised application
must be filed no later than December 31, 2026. See § 4262.10(d) of PBGC’s SFA regulation.
Plans in priority groups will be given the opportunity to file before March 11, 2023. See
PBGC’s website, www.pbgc.gov, for updated information on when plans in various priority
groups and plans not in any priority group may apply. Note: If you go to the e-Filing Portal
and do not see “Application for Financial Assistance – Special” under the “Select a Filing
Type,” then the e-Filing Portal is temporarily closed and PBGC is not accepting
applications (other than lock-in applications), unless the plan is eligible to make an
emergency filing under § 4262.10(f). PBGC’s website, www.pbgc.gov, will be updated
when the e-Filing Portal reopens for applications. PBGC maintains information on its
website to inform prospective applicants about the current status of the e-Filing portal, as
well as to provide advance notice of when PBGC expects to open or temporarily close the
e-Filing Portal.
In the event the e-Filing Portal is temporarily closed, the emergency filing process allows
PBGC to accept a priority application from a plan that is insolvent or expected to become
insolvent under section 4245(a) of ERISA within 1 year of filing an SFA application, or from a
plan that has implemented a suspension of benefits under section 305(e)(9) of ERISA as of
March 11, 2021. See § 4262.10(f) of PBGC’s SFA regulation. PBGC will accept emergency
filings from these plans during periods when PBGC would not otherwise accept such
applications. Before submitting an application under the emergency filing process, a filer must
send an email to the Multiemployer Program Division mailbox at
[email protected], and include as the subject “Emergency Filing, Special
Financial Assistance Application of (Plan Name).” In the email, the filer must substantiate the
claim of emergency status. Also in the email, the filer must provide a contact person’s name,
email address, and phone number. The contact person will receive further instructions from
PBGC as to how to submit the plan’s emergency application.
Information required for an application
The SFA application has five sections (Section A through Section E), which are described below.
Section A – Plan identifying information. This section requires the filer (e.g., accountant,
actuary, attorney, plan administrator, trustee) to input basic identifying plan information into the
e-Filing Portal.
Sections B through E. The filer must upload all required application files to the Documents
page of the e-Filing Portal and identify each document type from the dropdown list. The
Application for Approval of Special Financial Assistance Checklist (“SFA Application
Checklist”) identifies the specific document type to be selected for each item.
Section B – Plan documents. This section requires information that generally is readily available
to the plan sponsor, such as plan documents and actuarial valuation reports. It also requires an
enrollment form for the transfer of funds.

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Section C – Plan data. This section requires information that the filer must provide in Excel
compatible files. Links to the format and templates that may be used can be found throughout
these instructions.
Section D – Plan statements. This section requires information that the filer must provide in a
single, written document. On the SFA Application Checklist (Section E, Item (1)), the filer
must identify the page numbers of this written document that are responsive to each required
item.
Section E – Checklist, certifications, and SFA-related plan amendments. This section requires
the filer to complete the SFA Application Checklist and identifies the various required
certifications, plan amendments related to SFA, and other information.
Note: If required information was already filed: (1) through PBGC's e-Filing Portal; or (2)
through any means for an insolvent plan, a plan that has received a partition, or a plan that
submitted an emergency filing, the filer may either upload the information with the SFA
application or include a statement on the SFA Application Checklist that indicates the date
on which and the submission with which the required information was previously filed.
If, while the application is pending, the plan sponsor becomes aware of information
that is no longer accurate or that has been omitted from the application, it must notify
PBGC. See § 4262.6(e)(3) of PBGC’s SFA regulation.
SECTION A – Plan identifying information. The filer inputs the following information
into the e-Filing Portal.
(1) Plan name.
(2) Employer identification number (EIN).
(3) Plan number (PN).
(4) Notice filer name. Name of the individual authorized to file the SFA application.
(5) Role of filer. Relation of the individual filing the SFA application to the plan (e.g.,
accountant, actuary, attorney, plan administrator, trustee).
(6) Total amount requested. Amount of total SFA requested under § 4262.4(a)(1) or
§ 4262.4(a)(2) of PBGC’s SFA regulation. This figure should match the amount reported
in Section E, Item (5).
SECTION B – Plan documents. The filer uploads the following documents to the e-Filing
Portal, using where applicable the required filenames identified on the SFA Application
Checklist.
(1) Plan documentation.
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a. Most recent plan document or restatement of the plan document and all
amendments adopted since the last restatement (if any).
b. Most recent trust agreement or restatement of the trust agreement and all
amendments adopted since the last restatement (if any).
c. Most recent IRS determination letter.
(2) Actuarial valuation reports. Actuarial valuation report for the 2018 plan year and each
subsequent actuarial valuation report completed before the filing date of the initial
application. Provide each report as a separate document.
(3) Rehabilitation plan or funding improvement plan. Most recent rehabilitation plan or, if
applicable, funding improvement plan, including all subsequent amendments and
updates, and the percentage of total contributions received under each schedule of the
rehabilitation plan or funding improvement plan for the most recent plan year
available. If the most recent rehabilitation plan does not include historical
documentation of rehabilitation plan changes (if any) that occurred in calendar year
2020 and later, provide these details in a clearly identified additional document.
Provide each rehabilitation or funding improvement plan as a separate document.
(4) Form 5500. Most recently filed (as of the filing date of the initial application) Form
5500 and all schedules and attachments, including the audited financial statements.
Provide as a single document.
(5) Zone certifications. Plan actuary’s certification of plan status for the 2018 plan year
and each subsequent annual certification completed before the filing date of the initial
application, with documentation supporting each actuarial certification of plan status.
The documentation supporting each actuarial certification must clearly identify all
assumptions used, including the interest rate used for funding standard account
purposes; such identification may be provided in an addendum (in which case,
addendums are only required for the most recent actuarial certification of plan status
completed before January 1, 2021, and all subsequent annual certifications) or by
reference to other submitted materials such as an actuarial valuation report. Separately
identify as “additional information” all information included with the zone
certification to comply with this Section B, Item (5) that was not part of the original
zone certification. Provide each zone certification (including its identified additional
information) as a single document, separately for each plan year.
Documentation supporting a certification of critical and declining status must include
a plan-year-by-plan-year projection demonstrating the plan year that the plan is
projected to become insolvent. Provide the required plan-year-by-plan-year
projection for each certification separately and identify the fair market value of plan
assets as of the beginning and end of each plan year within the relevant period
described in section 305(b)(6) of ERISA. Also, identify the following cash-flow
items for each of those years:
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a.
b.
c.
d.
e.
f.

Contributions.
Withdrawal liability payments.
Benefit payments.
Administrative expenses.
Amount of net investment returns.
Investment return assumption.

(6) Account statements. Most recent statement for each of the plan’s cash and
investment accounts.
(7) Plan’s financial statement. Most recent plan financial statement (audited, or
unaudited if audited is not available).
(8) Withdrawal liability documentation. All of the plan’s written policies and procedures
governing determination, assessment, collection, settlement, and payment of withdrawal
liability. Provide all items as a single document.
(9) Death Audit. Documentation of a death audit to identify deceased participants that was
completed no earlier than one year before the plan’s SFA measurement date, including
identification of the service provider conducting the audit and a copy of the results of the
audit provided to the plan administrator by the service provider. If personally identifiable
information is included in this report, the filer must redact it before submission to PBGC.
(10) Automated Clearing House (ACH) Vendor/Miscellaneous Payment Enrollment Form and
required notarized bank letter. This ACH form is used to enable the plan to receive
electronic transfer of funds, if the SFA application is approved. When transferring funds,
PBGC will use ACH process or Fedwire process (preferred) for amounts up to $100
million (if further information is required for a sub account i.e., “further credit to” a
Fedwire is required), and only Fedwire process for amounts over $100 million. If the plan
is requesting SFA in an amount that is over $100 million, then the filer must confirm the
bank’s routing number listed on the ACH form for a Fedwire transfer and any other
information necessary for the transfer.
In addition to the plan’s completed, signed ACH payment form, the plan’s bank official
must include a notarized bank letter on bank letterhead with signature of the bank official.
The banking information in the ACH form must match the notarized bank letter by the
bank official. The notarized letter should contain the following information:
• Name and email address of a point of contact at the bank (used for PBGC to confirm
receipt of funds);
• Depositor Account Title;
• Name on bank account; i.e., no numerical characters
• Bank routing number;
• Bank account number;
• Any special instructions such as “for further credit instructions”; and
• Indicate if the banking instructions provided can accept ACH, Fedwire, or both
payment types.
If a plan closes the bank account that it listed on this form before PBGC transfers the SFA,
then the plan must notify PBGC immediately and submit an updated form with notarization.
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SECTION C – Plan data. The filer completes and uploads an Excel compatible file to the
e-Filing Portal for each item below, using, where applicable, the required filenames identified on
the SFA Application Checklist. The filer may use the templates specified with each item.
(1) Form 5500 projection. Template 1: For the 2018 plan year until the most recent plan year
for which the Form 5500 is required to be filed by the filing date of the initial application,
the projection of expected benefit payments as required to be attached to the Form 5500
Schedule MB if the response to line 8b(1) of the Form 5500 Schedule MB should be “Yes.”
(2) Contributing employers. Template 2: If the plan has 10,000 or more participants, as
required to be entered on line 6f of the plan’s most recently filed Form 5500 (by the filing
date of the initial application), a listing of the 15 largest contributing employers (the
employers with the largest contribution amounts) and the amounts of contributions paid
by each of these employers during the most recently completed plan year (before the
filing date of the initial application). For example, if a calendar year plan filed an
application on April 1, 2023, the plan would look to line 6f of the 2021 Form 5500 filed
in 2022. If line 6f of the 2021 Form 5500 showed 10,000 or more participants, the plan
must list the 15 contributing employers with the largest contributions and the amounts of
the contributions made by each of those employers during 2022, without regard to
whether a contribution was made on account of a year other than 2022. Alternatively, the
plan may choose to provide the listing of the 15 largest contributing employers and the
amounts of contributions paid by each of these employers on account of the most recently
completed plan year. Identify the basis (cash or accrual) used to report the employer
contributions. If the plan is required to provide this information, it is required for the 15
largest contributing employers even if the employer’s contribution is less than 5% of total
contributions.
(3) Historical plan information. Template 3: Historical plan information for the 2010 plan
year through the plan year immediately preceding the date the plan’s initial application
was filed that separately identifies: total contributions, total contribution base units
(including identification of the unit used (i.e., hourly, weekly)), average contribution
rates, and number of active participants at the beginning of each plan year. Also, show
separately for each of the plan years in the same period all other sources of noninvestment income, including, if applicable, withdrawal liability payments collected,
reciprocity contributions (if applicable), additional contributions pursuant to the
rehabilitation plan (if applicable), and other identifiable contribution streams.
(4) SFA determination. Template 4A: The calculation of the amount of SFA differs for
different eligible plans, as follows:
•

Plans that are not MPRA plans – “basic method.” For a plan that does not
meet the definition of a “MPRA plan” under § 4262.4(a)(3) of PBGC’s SFA
regulation, the amount of SFA is determined under the “basic method”
described in § 4262.4(a)(1) of PBGC’s SFA regulation.

•

MPRA plans. For a plan that meets the definition of a “MPRA plan” under
§ 4262.4(a)(3) of PBGC’s SFA regulation, the amount of SFA determined
under § 4262.4(a)(2) of PBGC’s SFA regulation is the greatest of the three
amounts calculated using the “basic method” determined under § 4262.4(a)(1)
of PBGC’s SFA regulation, the “increasing assets method” determined under
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§ 4262.4(a)(2)(i), and the “present value method” determined under
§ 4262.4(a)(2)(ii).
All plans must provide the information described below for the “basic method” and may
use Template 4A. MPRA plans must provide additional information, including the
amount of SFA calculated using the “increasing assets method”, using the format of
Template 4A, as described in Addendum D. A MPRA plan that calculates the greatest
amount of SFA using the “present value method” must provide additional information
using the format of Template 4B, as described in Addendum D.
Provide information used to determine the amount of SFA for the plan using the “basic
method” described in § 4262.4(a)(1) of PBGC’s SFA regulation based on a deterministic
projection and using the actuarial assumptions as described in § 4262.4(e) of PBGC’s
SFA regulation. The information to be provided is:
a. The amount of SFA calculated using the “basic method”, determined as a lump
sum as of the SFA measurement date.
b. Non-SFA interest rate required under § 4262.4(e)(1) of PBGC’s SFA regulation,
including supporting details on how it was determined.
c. SFA interest rate required under § 4262.4(e)(2) of PBGC’s SFA regulation,
including supporting details on how it was determined.
d. Fair market value of assets as of the SFA measurement date. This amount should
include any assets at the SFA measurement date attributable to financial
assistance received by the plan under section 4261 of ERISA on or before the
SFA measurement date, but it should not reflect a payable for amounts owed to
PBGC for any amounts of such financial assistance received by the plan.
e. For each plan year in the period beginning on the SFA measurement date and
ending on the last day of the last plan year ending in 2051 (the “SFA coverage
period”):
i. Separately identify the projected amount of contributions, projected
withdrawal liability payments reflecting a reasonable allowance for
amounts considered uncollectible, and other payments expected to be
made to the plan (excluding the amount of financial assistance under
section 4261 of ERISA and SFA to be received by the plan).
ii. Identify the benefit payments described in § 4262.4(b)(1) (including any
benefits that were restored under 26 CFR 1.432(e)(9)-(1)(e)(3) and
excluding the make-up payments in Item (4)e.iii. below), separately for
current retirees and beneficiaries, current terminated vested participants
not yet in pay status, current active participants, and new entrants; and
total benefit payments paid and expected to be paid from projected SFA
assets separately from total benefit payments paid and expected to be paid
from non-SFA assets after the projected SFA assets are fully exhausted.
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iii. Separately identify the make-up payments described in § 4262.4(b)(1)
attributable to the reinstatement of benefits under § 4262.15 that were
previously suspended through the SFA measurement date.
The following example provides additional information about how to
determine the amounts to be provided in Section C, Items (4)e.ii. and
(4)e.iii. for reinstatement of benefits previously suspended under sections
305(e)(9) or 4245(a) of ERISA.
Example – Joe is a retiree who was receiving a monthly benefit of $2,000
per month payable as a straight life annuity on the first of each month
until a benefit suspension took effect on 1/1/2019. Starting on 1/1/2019,
his benefit was reduced to $1,000 per month. The SFA measurement date
is 12/31/2021, which means that, as of the SFA measurement date, 36
months of benefit payments have been suspended (from 1/1/2019 through
12/31/2021).
The plan decides to restore benefits at the latest possible date, so the
monthly benefit paid to Joe will not increase to the original $2,000 per
month until the first of the month in which the SFA is paid to the plan (see
§ 4262.15(a)(1)). Also, the “make-up” payment will cover the period
from 1/1/2019 through the month preceding the month in which the SFA
is paid.
However, for purposes of determining the SFA amount, only, under
§ 4262.4, calculations are performed as if the projected benefit begins the
day after the SFA measurement date as shown below:
Scenario A – Plan elects to pay the make-up payment as a single lump
sum
Step 1 – The projected benefits to be provided in Section C, Item (4)e.ii.
will reflect $2,000 per month payable to Joe starting on 1/1/2022 for the
remainder of his life.
Step 2 – The benefit payment to be provided in Section C, Item (4)e.iii.
will be $36,000, the make-up payment assumed to be paid as of the SFA
measurement date of 12/31/2021.
Scenario B – Plan elects to pay the make-up payment in equal monthly
installments over 5 years
Step 1 – The projected benefits provided in Section C, Item (4)e.ii. will
reflect $2,000 per month payable to Joe starting on 1/1/2022 for the
remainder of his life.
Step 2 – The make-up payment is paid in 60 equal monthly installments of
$600 ($36,000 divided by 60). The benefits to be provided in Section C,
Item (4)e.iii. will reflect $600 per month payable to Joe (or his designated
beneficiary) starting on 1/1/2022 for 60 months.
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iv. Separately identify administrative expenses paid and expected to be paid
(excluding the amount owed PBGC under section 4261 of ERISA) for
premiums to PBGC and for all other administrative expenses; and identify
total administrative expenses paid and expected to be paid from projected
SFA assets separately from total administrative expenses paid and
expected to be paid from non-SFA assets after the projected SFA assets
are fully exhausted.
v. Provide the projected total participant count at the beginning of each plan
year.
vi. Provide the projected investment income earned by assets not attributable
to SFA based on the non-SFA interest rate in Section C, Item (4)b. and the
projected fair market value of non-SFA assets at the end of each plan
year.
vii. Provide the projected investment income earned by assets attributable to
SFA based on the SFA interest rate in Section C, Item (4)c. (excluding
investment returns for the plan year in which the sum of the annual
projected benefit payments and administrative expenses for the year
exceeds the beginning-of-year projected SFA assets) and the projected fair
market value of SFA assets at the end of each plan year.
f. The projected SFA exhaustion year. This is the first day of the plan year in which
the sum of annual projected benefit payments and administrative expenses for the
year exceeds the beginning-of-year projected SFA assets.
(5) Baseline details. Template 5A: This Template 5A is required (except as noted in the
next paragraph) for plans that are not MPRA plans. See Addendum D for separate
instructions for Baseline details to be submitted for MPRA plans.
This item is not required if all assumptions and methods used to determine the requested
SFA amount are identical to those used in the most recent actuarial certification of plan
status completed before January 1, 2021 (“pre-2021 certification of plan status”), except
the non-SFA and SFA interest rates, and except any assumptions that were changed in
accordance with Section III, Acceptable Assumption Changes, in PBGC’s SFA
assumptions guidance (other than the acceptable assumption change for “missing”
terminated vested participants described in Section III.E of PBGC’s SFA assumptions
guidance).
Provide a separate deterministic projection (“Baseline”) in the same format as Section C,
Item (4) that shows the amount of SFA using the basic method (§ 4262.4(a)(1) of
PBGC’s SFA regulation) that would be determined if all underlying assumptions and
methods used in the projection were the same as those used in the pre-2021 certification
of plan status, except the plan’s non-SFA interest rate and SFA interest rate, which
should instead be the same as used in Section C, Item (4). For purposes of Section C,
Item (5), any assumption change made in accordance with Section III, Acceptable
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Assumption Changes, in PBGC’s SFA assumptions guidance should be reflected in this
Baseline calculation of the SFA amount and supporting projection information, except
that an assumption change for “missing” terminated vested participants described in
Section III.E of PBGC’s SFA assumptions guidance should not be reflected in the
Baseline projections
Assumption changes made in accordance with Section IV, Generally Accepted
Assumption Changes, in PBGC’s SFA assumptions guidance should not be reflected in
this Baseline calculation. See the example below.
Example – Plan A applies for SFA in 2025 with an SFA measurement date of
12/31/2024. Plan A’s actuary prepared an actuarial certification of plan status on
3/15/2020 for the plan year beginning 1/1/2020. This is the most recent certification of
plan status before 1/1/2021. In that certification, the plan’s status is critical and
declining, and the plan is projected to become insolvent within 8 years.
When calculating the amount of requested SFA, the plan actuary uses the same
assumptions that were used to prepare the actuarial certification of plan status on
3/15/2020 except for the following changes in assumptions:
•

The funding standard account interest rate used in the pre-2021 certification is
6.00%. Assume that the applicable interest rate limit in § 4262.4(e)(1)(ii) of
PBGC’s SFA regulation is 5.50%, and the applicable interest rate limit in
§ 4262.4(e)(2)(ii) of PBGC’s SFA regulation is 3.50%. The SFA amount will be
calculated using a non-SFA interest rate of 5.50% and an SFA interest rate of
3.50%.

•

The mortality table used in the pre-2021 certification is the RP-2000 Mortality
Table with projected improvements through 2025 using Scale AA. The plan
actuary determines the mortality assumption used in this certification is no longer
reasonable and proposes changing to the Pri-2012 amount-weighted Blue Collar
table (Pri-2012(BC)) with projected improvements based on a mortality
improvement scale published in 2024 by the Retirement Plans Experience
Committee of the Society of Actuaries.

•

Since the pre-2021 certification projected the plan to be insolvent within 8 years,
the plan actuary must adopt assumptions to project administrative expenses and
CBUs to the end of the SFA coverage period. The plan actuary adopts the
assumptions for administrative expenses in Section III, Acceptable Assumption
Changes, in PBGC’s SFA assumptions guidance to project administrative
expenses through 2051. The plan actuary adopts a CBU assumption based on
information provided by the plan sponsor. The CBU assumption meets the
criteria in Section IV.A, Generally Acceptable Assumption Changes, Proposed
Change to CBU Assumption, in PBGC’s SFA assumptions guidance, but the
changed CBU assumption does not meet the criteria in Section III, Acceptable
Assumption Changes, in PBGC’s SFA assumptions guidance.
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•

Since the pre-2021 certification projected the plan to be insolvent within 8 years,
the plan actuary only had an assumption for withdrawal liability payments during
those 8 years, and must extend the assumption to project withdrawal liability
payments expected to be received by the plan to the end of the SFA coverage
period. With input from the plan sponsor, the plan actuary develops a 30-year
projection reflecting a reasonable allowance for amounts considered
uncollectible.

•

The plan actuary determines that the assumed retirement rates and payment form
assumptions used in the pre-2021 certification are no longer reasonable and
makes changes to each of these assumptions based on an analysis of plan
experience and reasonable expectations.

The projections to be provided for Section C, Item (5) – Baseline – should reflect the
following assumptions:
•

Non-SFA interest rate: 5.50%

•

SFA interest rate: 3.50%

•

Mortality: Pri-2012(BC) with mortality improvement scale published in 2024 by
the Retirement Plans Experience Committee of the Society of Actuaries. This
assumption change is included in the Baseline because it is in Section III,
Acceptable Assumption Changes, in PBGC’s SFA assumptions guidance.

•

Extended CBU assumption: The CBU assumption to be shown in the Baseline
projections should reflect the “extension” of the CBU assumption that is
consistent with Paragraph A, “Adoption of assumptions not previously factored
into pre-2021 certification of plan status,” of Section III, Acceptable Assumption
Changes, in PBGC’s SFA assumptions guidance.

•

Extended administrative expense assumption: This assumption change is included
in the Baseline because it is in Section III, Acceptable Assumption Changes, in
PBGC’s SFA assumptions guidance.

•

All other assumptions used in the projections should be the same assumptions
used in the pre-2021 certification.

All other assumption changes that are reflected in the calculation of the SFA amount in
Section C, Item (4) (e.g., change in CBU assumptions that is different than the
“acceptable” extension, new withdrawal liability payments, retirement rates and
assumed payment forms) should not be included in the Baseline information.
(6) Reconciliation details. Template 6A: This Template 6A is required (except as noted in
the next paragraph) for plans that are not MPRA plans. See Addendum D for separate
instructions for Reconciliation details to be submitted for MPRA plans.
This item is not required if all assumptions and methods used to determine the requested
SFA amount are identical to those used in the pre-2021 certification of plan status,
12

except the non-SFA and SFA interest rates, and except any assumptions changed in
accordance with Section III, Acceptable Assumption Changes, in PBGC’s SFA
assumptions guidance (other than the acceptable assumption change for “missing”
terminated vested participants described in Section III.E of PBGC’s SFA assumptions
guidance). This item is also not required if the requested SFA amount from Section C,
Item (4) is the same as the amount shown in the Baseline details of Section C, Item (5).
If the assumptions/methods used to determine the requested SFA amount differ from
those in the “Baseline” projection in Section C, Item (5), then provide a reconciliation of
the change in the total amount of SFA due to each change in assumption/method from the
Baseline to the requested SFA as shown in Section C, Item (4). For each
assumption/method change from the Baseline through the requested SFA amount,
provide a deterministic projection in the same format as Section C, Item (4). Detailed
explanations and supporting rationale and information for each assumption/method
change is required in Section D, Item (6)b.
Example – Consider the same Plan A example in Section C, Item (5) above. When
completing this Section C, Item (6), the reconciliation should show the change in SFA
(and corresponding projection information) for each of the assumption changes not
reflected in the Baseline – change in CBU assumptions from the “extended” acceptable
assumption to the CBU assumption used to determine the requested SFA as shown in
Section C, Item (4), change in withdrawal liability payments, change in retirement rates,
and change in assumed payment forms. Below is an example of the reconciliation
information to be shown:
Item number

Basis for
Assumptions/Methods

1
2
3
4
5

Baseline
CBU
Withdrawal Liability
Retirement
Payment form

Change in SFA Amount
(in $million)
(from prior item number)
N/A
$3.0
$(0.2)
$0.7
$0.2

SFA Amount
(in $million)
$6.0
$9.0
$8.8
$9.5
$9.7

(7) Assumption/method changes. Template 7:
a. This item is not required if the plan is eligible for SFA under § 4262.3(a)(2) or
§ 4262.3(a)(4) of PBGC’s SFA regulation or if the plan is eligible based on a
certification of plan status completed before January 1, 2021. This item is also
not required if the plan is eligible based on a certification of plan status for SFA
eligibility purposes completed after December 31, 2020, but reflects the same
assumptions as those in the pre-2021 certification of plan status.
A table identifying which assumptions (and methods) used in determining the
plan’s eligibility for SFA differ from those used in the pre-2021 certification of
13

plan status and brief explanations as to why using those original
assumptions/methods is no longer reasonable and why the changed
assumptions/methods are reasonable. This should be an abbreviated version of
information provided in Section D, Item (6)a.
b. A table identifying which assumptions (and methods) used in calculating the
amount of SFA differ from those used in the pre-2021 certification of plan status
(except the interest rates used to determine SFA) and brief explanations as to why
using those original assumptions is no longer reasonable and why the changed
assumptions are reasonable. Please state if the changed assumption is an
extension of the CBU assumption or the administrative expenses assumption as
described in Paragraph A, “Adoption of assumptions not previously factored into
pre-2021 certification of plan status,” of Section III, Acceptable Assumption
Changes, in PBGC’s guidance on Special Financial Assistance Assumptions.
This should be an abbreviated version of information provided in Section D, Item
(6)b.
Example – Consider the same Plan A example in Section C, Item (5) above.
When completing Section C, Item (7)b., the plan should identify all assumption
changes (except the interest rates) -- including those reflected in the Baseline.
Assumption That Has Changed From
Assumption Used in Most Recent
Certification of Plan Status Completed
Before 1/1/2021
Mortality
Administrative Expenses
CBU
Withdrawal Liability
Retirement
Payment Form
(8) Contributions and withdrawal liability details. Template 8: Provide details of the
projected contributions and withdrawal liability payments used to calculate the requested
SFA amount. This should include total contributions, contribution base units (including
identification of base unit used (i.e., hourly, weekly)), average contribution rate(s),
reciprocity contributions (if applicable), additional contributions from the rehabilitation
plan (if applicable), and any other identifiable contribution streams. Provide the
projected number of active participants at the beginning of each plan year. For
withdrawal liability, separately show amounts for currently withdrawn employers and for
future assumed withdrawals.
(9) Participant data. For plans with 350,000 or more participants reported on line 6f of the
most recently filed Form 5500, provide the full individual participant census data (do not
14

provide any personally identifiable information) utilized by the plan actuary in
developing the cash flow projections included in the application.
SECTION D – Plan statements. The filer uploads a single document (with a unique page
number on each page of the document) as document type “Special Financial Assistance
Application” to the e-Filing Portal with responses to the following information requirements.
This document must be signed and dated by an authorized trustee who is a current member of the
board of trustees or an authorized representative of the plan sponsor and include the printed
name and title of the signer.
(1) Provide an SFA request cover letter for the application (optional, except as follows):
a

For a MPRA plan, include an SFA request cover letter that identifies the
calculation method (basic method, increasing assets method, or present value
method) that provides the greatest amount of SFA. See Section C, Item (4).

b

For a MPRA plan with a partition, include an SFA request cover letter that
includes a statement that the plan has been partitioned under section 4233 of
ERISA.

(2) Provide the name, address, email, and telephone number of the plan sponsor and the plan
sponsor’s authorized representative, and any other authorized representatives.
(3) Identify which of the following eligibility criteria qualify the plan to be eligible for SFA.
Provide additional information as required below for each item that is applicable. If the
plan is eligible for SFA under multiple criteria, the filer may (but is not required to)
identify and provide the required additional information for more than one.
a. In any plan year beginning in 2020, 2021, or 2022, the plan is certified by the plan
actuary to be in critical and declining status. Identify which plan year(s) apply
and refer to information required in Section B, Item (5) and if applicable, Section
E, Item (2).
b. The plan has been approved for a suspension of benefits under section 305(e)(9)
of ERISA as of March 11, 2021.
c. The plan satisfies the eligibility requirements for a critical status plan under
§ 4262.3(a)(3) of PBGC’s SFA regulation. The conditions do not need to be
satisfied for the same plan year.
i. In any plan year beginning in 2020, 2021, or 2022, the plan is certified by
the plan actuary to be in critical status. Identify the specified year(s) and
refer to information required in Section B, Item (5) and if applicable
Section E, Item (2).
ii. The percentage calculated under § 4262.3(c)(2) of PBGC’s SFA
regulation for 2020, 2021, or 2022 is less than 40 percent. Identify which
year’s Form 5500 Schedule MB is used by the plan for eligibility; the
current value of net assets entered by the plan on line 2a of the Form 5500
15

Schedule MB; the current value of withdrawal liability due to be received
by the plan on an accrual basis, reflecting a reasonable allowance for
amounts considered uncollectible (if not already included in the current
value of net assets); and the current liability measurement entered by the
plan on line 2b(4) column (2) of the Form 5500 Schedule MB.
iii. On the Form 5500 that was required to be filed for plan year 2020, 2021,
or 2022, the ratio of active participants that is entered on line 6a(2) to
inactive participants (that is the sum of lines 6b, 6c, and 6e) is less than 2
to 3. Identify which year’s Form 5500 is used by the plan for eligibility
and the number of active participants entered by the plan on line 6a(2) and
the number of inactive participants that is the sum of lines 6b, 6c, and 6e.
Alternatively based on the Schedule MB of the Form 5500 that was
required to be filed for plan year 2020, 2021 or 2022, the ratio of the total
number of active participants at the beginning of the plan year that is
entered as the number of participants on line 2b(3)(c) to inactive
participants (that is the sum of retired participants and beneficiaries
receiving payment on line 2b(1) and terminated vested participants on line
2b(2)) is less than 2 to 3. Identify which year’s Schedule MB of the Form
5500 is used by the plan for eligibility and the number of active
participants entered by the plan on line 2(b)(3)(c) and the number of
inactive participants that is the sum of lines 2b(1) and 2(b)(2).
d. The plan became insolvent after December 16, 2014, and remained insolvent
without terminating as of March 11, 2021.
(4) If the plan’s application is submitted on or before March 11, 2023, identify which priority
group the plan is in (see § 4262.10(d)(2) of PBGC’s SFA regulation). If the plan is
submitting an emergency application under § 4262.10(f), identify the application as an
emergency application and which emergency criteria is applicable.
(5) Provide a detailed narrative description of the development of the assumed future
contributions (including assumed contribution rates) and the assumed future withdrawal
liability payments used to calculate the SFA amount as shown in Section C, Item (4).
(6) Provide the following:
a. If the plan is eligible for SFA under § 4262.3(a)(1) or § 4262.3(a)(3) of PBGC’s
SFA regulation, and the assumptions used to determine such eligibility are
different from the assumptions used in the most recent actuarial certification of
plan status completed before January 1, 2021, identify which assumptions are
different, and provide detailed explanations and supporting rationale and
information as to why using the identified assumptions is no longer reasonable
and why the changed assumptions are reasonable.
16

b. If any assumptions or methods used to determine the SFA amount are different
from those used in the most recent actuarial certification of plan status before
January 1, 2021 (excluding the plan’s non-SFA and SFA interest rates, which
must be the same as the interest rates required under § 4262.4(e)(1) and (2)),
identify which assumptions/methods are different, and provide detailed
explanations and supporting rationale and information as to why using the
identified original assumptions is no longer reasonable and why the changed
assumptions are reasonable. Please state if the changed assumption is an
extension of the CBU assumption or the administrative expenses assumption as
described in Paragraph A, “Adoption of assumptions not previously factored into
pre-2021 certification of plan status,” of Section III, Acceptable Assumption
Changes, in PBGC’s SFA assumptions guidance.
The information to be provided in Items (6)a. and (6)b. is intended to be a more
detailed explanation with supporting rationale and information than the brief
summary that is provided in Section C, Items (7)a. and (7)b.
Following are examples of supporting rationale and information for different
types of assumption changes:
•

For changes to demographic assumptions such as retirement and turnover
– experience study including detailed summary of actual experience and
documentation of data sources and methodologies used.

•

For changes to optional payment form assumptions – historical
distribution of payment form selected at retirement.

•

For changes to the new entrant profile – historical distribution (by year) of
ages of all new entrants (whether new hires or rehires) and other relevant
demographic characteristics such as service or pay.

•

For changes to contribution assumptions including CBUs and contribution
rates – narrative explanation of historical trends, rationale for assumption
and explanation of consistency between CBU assumptions, contribution
rates and assumed rates of future employer withdrawals.

•

For changes in assumed collectability of withdrawal liability – historical
data on collectability and, if applicable, how other relevant factors were
considered.

•

For changes in assumed rate of future employer withdrawals – relevant
historical data and, where appropriate, relevant industry or geographic
information.

•

For changes to the initial amount of administrative expenses, detailed
supporting rationale for the amount of change in each type of
administrative expense (e.g., legal, plan administration, office expenses,
etc.)

17

•

For changes to the assumption used to increase administrative expenses,
forward-looking expectations from credible sources.

•

For changes to the assumption for which terminated vested participants are
included or excluded from the determination of SFA, see PBGC’s SFA
assumptions guidance (Sections III.E and VI.C).

Supporting information to be provided if a plan-specific mortality table or a planspecific adjustment to a standard mortality table is used (regardless of if the
mortality assumption is changed or unchanged from the pre-2021 certification of
plan status) should comprehensively document the methodology used and
rationale for selection of the methodology used (including, but not limited to, the
selection of the base table and improvement scale, methodology for weighting of
mortality experience, method for adjusting the base table, experience period used,
and handling of different participant groups (e.g., gender, pay status)) to develop
the plan-specific rates, as well as detailed information showing the determination
of plan credibility and plan experience.
For any changed assumption for which future expectations differ significantly
from historical experience, provide rationale for the difference and supporting
information.
(7) This item is required only if the plan suspended benefits under section 305(e)(9) or
section 4245(a) of ERISA.
Provide a narrative description of how the plan will reinstate the benefits that were
previously suspended and a proposed schedule of payments (equal to the amount of
benefits previously suspended) to participants and beneficiaries under the plan. The
proposed schedule should show the yearly aggregate amount and timing of such
payments and assume for purposes of determining SFA only that the effective date for
reinstatement is no later than the day after the SFA measurement date, as shown under
Section C, Item (4)e. If the plan restored benefits under 26 CFR 1.432(e)(9)-1(e)(3)
before the SFA measurement date, the proposed schedule should reflect the amount and
timing of payments of restored benefits and the effect of the restoration on the benefits
remaining to be reinstated. For more information regarding the reinstatement of benefits,
see guidance issued by the Treasury Department and IRS (Notice 2021-38).
SECTION E – Checklist, certifications, and SFA-related plan amendments. The filer
completes and uploads the Application for Approval of Special Financial Assistance Checklist to
the e-Filing Portal, to ensure that the filer has uploaded the required information using, where
applicable, the required filenames identified on the SFA Application Checklist.
All certifications from the plan’s enrolled actuary should include, where applicable, clear
18

indication of all 1 assumptions and methods used, including source of and date of participant
census data, measurement date (where applicable) and a statement that the actuary is qualified to
render the actuarial opinion.
The filer uploads the following documents to the e-Filing Portal.
(1) SFA Application Checklist.
(2) SFA Eligibility Certification and Supporting Information for Critical and Declining Plan.
If the plan claims SFA eligibility under § 4262.3(a)(1) of PBGC’s SFA regulation based
on the certification from the plan’s enrolled actuary of plan status completed before
January 1, 2021, no information is required for this Item (2), but the applicable zone
certification and supplemental information should be provided in Section B, Item (5).
If the plan claims SFA eligibility under § 4262.3(a)(1) of PBGC’s SFA regulation based
on a certification by the plan’s enrolled actuary of plan status for SFA eligibility purposes
completed on January 1, 2021, or later, the following items should be included as a single
document for this Item (2).
a. Plan actuary’s certification of plan status for SFA eligibility purposes for the
specified year (and, if applicable, for each plan year after the plan year for which
the pre-2021 zone certification was prepared and for the plan year immediately
prior to the specified year). For example, if the specified year used for SFA
eligibility purposes is the 2022 plan year, and the pre-2021 zone certification is
for the 2020 plan year, then provide the plan actuary’s certification of plan status
for SFA eligibility purposes for the 2021 and 2022 plan years.
b. For each certification in a. above, include all details and additional information as
described in Section B, Item (5), including clear documentation of all
assumptions, methods and census data used.
c. For each certification in a. above, identify of all assumptions and methods that are
different from those used in the pre-2021 zone certification.

Identify all demographic assumptions used (e.g., healthy mortality, disabled mortality, mortality improvement,
retirement for actives, retirement for terminated vested participants, turnover, disability, assumed payment form
for actives, assumed payment form for terminated vested participants, marital status, spouse age difference, and
new entrant profile). Also identify the assumption used for projecting active participant counts. Identify how
missing or incomplete data is handled or state that there is no missing or incomplete data. Identify whether any
plan participants are excluded from the projections, or state that there are no exclusions. Clearly state the
participant census date. Identify projection assumptions including CBUs, contribution rates and whether
contribution rates are the current rates in CBAs in effect as of July 9, 2021, administrative expenses, and
withdrawal liability payments (separately for currently withdrawn employers and future assumed withdrawals).
Identify any assumptions related to reciprocity, or state there are no such assumptions and why.

1

19

(3) SFA Eligibility Certification and Supporting Information for Critical Plan. If the plan
claims SFA eligibility under § 4262.3(a)(3) of PBGC’s SFA regulation, the following
items should be included as a single document for this Item (3).
a. If the plan claims SFA eligibility under § 4262.3(a)(3) of PBGC’s SFA regulation
based on a certification by the plan’s enrolled actuary of plan status completed
before January 1, 2021, the zone certification and additional information provided
in Section B, Item (5) is sufficient and does not need to be separately provided
here.
If the plan claims SFA eligibility under § 4262.3(a)(3) of PBGC’s SFA regulation
based on a certification by the plan’s enrolled actuary of plan status for SFA
eligibility purposes completed on January 1, 2021, or later, include here the same
information identified in Item (2)a., b., and c. above.
b. A certification from the plan’s enrolled actuary that the plan qualifies for SFA
based on the applicable certification of plan status for SFA eligibility purposes for
the specified year, and by meeting the other requirements of § 4262.3(c) of
PBGC’s SFA regulation. The certification should specifically note the specified
year for each component of eligibility (certification of plan status for SFA
eligibility purposes, modified funding percentage, and participant ratio), the
derivation of the modified funded percentage, and the derivation of the participant
ratio. The certification must identify all assumptions and methods (including
supporting rationale, and where applicable, reliance on the plan sponsor) used to
develop the current value of the withdrawal liability that is utilized in the
calculation of the modified funded percentage.
(4) Priority Status. This actuarial certification is not required if the plan is insolvent under
section 4245(a) of ERISA, or has implemented a suspension of benefits under section
305(e)(9) of ERISA as of March 11, 2021, or is in critical and declining status (as defined
in section 305(b)(5) of ERISA) and had 350,000 or more participants, or is listed on
PBGC’s website at www.pbgc.gov as a plan in priority group 6 as defined under
§ 4262.10(d)(2)(vi).
If the plan is filing an application on or before March 11, 2023, a certification from the
plan’s enrolled actuary that the plan is eligible for priority status, with specific
identification of the applicable priority group. This certification should include sufficient
information to demonstrate that the plan is eligible for the identified priority group,
including details of relevant plan projections and clear documentation of all assumptions,
methods, and census data used in such projections.
(5) SFA Amount Certification. A certification from the plan’s enrolled actuary that the
requested amount of SFA is the amount to which the plan is entitled. The following
items should be included as a single document for this Item (5).
20

a. Plan actuary’s certification that identifies the requested amount of SFA and
certifies that this is the amount to which the plan is entitled under section
4262(j)(1) of ERISA and § 4262.4 of PBGC’s SFA regulation.
b. For a MPRA plan, identification of the amount of SFA determined under the
“basic method” described in § 4262.4(a)(1) of PBGC’s SFA regulation and the
“increasing assets method” under § 4262.4(a)(2)(i).
c. For a MPRA plan, if the amount of SFA determined under the “present value
method” described in § 4262.4(a)(2)(ii) is not the greatest amount of SFA under
§ 4262.4(a)(2), a statement certifying as such.
d. For a MPRA plan, if the amount of SFA determined under the “present value
method” described in § 4262.4(a)(2)(ii) is the greatest amount of SFA under
§ 4262.4(a)(2), identification of the amount of SFA determined under the “present
value method”.
e. Identify all assumptions and methods used, including the SFA measurement date
and other relevant information. Provide a summary of and identify the sources of
participant census data used, including the participant census date.
(6) Fair Market Value Certification. A certification from the plan sponsor with respect to the
accuracy of the amount of the fair market value of assets as of the SFA measurement
date, including relevant supporting information. For MPRA plans, this certification is
required even if the requested SFA amount is based on the “present value method” under
§ 4262.4(a)(2)(ii) of PBGC’s SFA regulation. The following items should be included as
a single document for this Item (6).
a. Plan sponsor’s certification that explicitly identifies and certifies the amount of
the fair market value of assets as of the SFA measurement date that is used in the
calculation of the SFA amount using the “basic method” and, if applicable, the
“increasing assets method”.
b. Information that substantiates the asset value and how it was developed (e.g., trust
or account statements, specific details of any adjustments).
c. If the SFA measurement date is later than the end of the plan year for the most
recent audited plan financial statements, provide a reconciliation of the fair
market value of assets from the date of the most recent audited plan financial
statements to the SFA measurement date. The reconciliation should show the
beginning and ending fair market value of assets for this period, as well as the
following items for the period: contributions, withdrawal liability payments,
benefits paid, administrative expenses, and investment income. The
reconciliation should also identify changes (with explanations), if any, to payables
or receivables reflected in the audited plan financial statements.
(7) Executed Plan Amendment for SFA Compliance. A copy of the executed plan
amendment required by § 4262.6(e)(1) of PBGC’s SFA regulation which (i) is signed by

21

an authorized trustee of the plan and (ii) includes the following provision, which must be
effective through the end of the last plan year ending in 2051: “Beginning with the SFA
measurement date selected by the plan in the plan's application for special financial
assistance, notwithstanding anything to the contrary in this or any other governing
document, the plan shall be administered in accordance with the restrictions and
conditions specified in section 4262 of ERISA and 29 CFR part 4262. This amendment
is contingent upon approval by PBGC of the plan's application for special financial
assistance.” A model plan amendment that includes the required information is available
here.
(8) Proposed Plan Amendment to Reinstate Benefits. In the case of a plan that suspended
benefits under section 305(e)(9) or section 4245(a) of ERISA, the following items should
be included as a single document for this Item (8).
a. The proposed plan amendment(s) to reinstate suspended benefits and pay makeup payments, required by § 4262.6(e)(2) of PBGC’s SFA regulation. A model
proposed plan amendment that includes the required information is available here.
b. A certification by the plan sponsor that the proposed plan amendment(s) to
reinstate suspended benefits and pay make-up payments will be timely adopted.
A model certification that includes the required information is available here.
c. The certification in b. must be signed either by all members of the plan’s board of
trustees or by one or more trustees duly authorized to sign the certification on
behalf of the entire board and to commit the board to timely adopting the
amendment after the plan’s application for SFA is approved, with each signature
accompanied by the printed name and title of the signer.
d. If such certification is not signed by all members of the board of trustees,
documentation that substantiates the authority of one or more trustees duly
authorized to sign on behalf of the entire board.
(9) Executed Plan Amendment to Rescind Partition Order. In the case of a plan that was
partitioned under section 4233 of ERISA that is eligible for SFA under § 4262.3(a)(2) of
PBGC’s SFA regulation, a copy of the executed plan amendment which (i) is signed by
an authorized trustee of the plan and (ii) removes any provisions or amendments that
were required to be adopted under the partition order, as required by § 4262.9(c)(2) of
PBGC’s SFA regulation, which also includes the following: “This amendment is
contingent upon approval by PBGC of the plan's application for special financial
assistance.”
(10) One or more copies of the following statement that: (a) is signed by an authorized trustee
who is a current member of the board of trustees, (b) includes the trustee’s printed name
and title, and (c) reads:

22

“Under penalty of perjury under the laws of the United States of America, I declare that I
have examined this application, including accompanying documents, and, to the best of
my knowledge and belief, the application contains all the relevant facts relating to the
application, all statements of fact contained in the application are true, correct, and not
misleading because of omission of any material fact; and all accompanying documents
are what they purport to be.”
What happens after an application is filed
After an application is filed, the filer will hear from PBGC within 120 days of the filing date.
The application will be either approved or denied. If the application is approved, the plan will
receive further instructions from PBGC on how the SFA amount will be transferred. If the
application is denied, the filer will receive written notice from PBGC providing the reasons for
the denial. PBGC may deny an application because it is incomplete; because an assumption is
unreasonable, a proposed change in assumption is unreasonable individually, or the proposed
changed assumptions are unreasonable in the aggregate; or because the plan is not an eligible
multiemployer plan. The filer then may submit a revised application no later than December 31,
2026.
An authorized filer may withdraw an application at any time before PBGC denies or approves
the application. To withdraw an application, the filer must send an email to the Multiemployer
Program Division mailbox at [email protected] and include as the subject
“Withdrawal of Special Financial Assistance Application of (Plan Name).” The body of the
email should read, “On behalf of (Plan Name), I withdraw the special financial assistance
application filed on (filing date)” and include the filer’s title, relation to the plan, and other
information to demonstrate that the filer is an individual authorized to withdraw the SFA
application. If a filer decides to submit an application following withdrawal, then the newly filed
application will be considered a revised application. For the revised application, the filer needs
to submit only the information that is changed from the initial application. The filer may state on
the SFA Application Checklist that other information was previously filed.
A revised application for SFA must use the same SFA measurement date, participant census
data, non-SFA interest rate, and SFA interest rate as were used in the plan’s initial application
(this is the plan’s “base data,” see § 4262.11(c)). Also, if a plan received a transfer of benefit
liabilities from another plan that previously filed an initial application for SFA, then PBGC will
treat the transferee plan’s application as a revised application and require the revised application
to use the base data of the transferor plan’s initial application.
An interim final rule filer (“IFR filer”) described under § 4262.4(g) of PBGC’s SFA regulation
that files a revised application must use the following base data, see § 4262.4(g)(5):
(1) The plan’s SFA measurement date determined as the last day of the calendar quarter
immediately preceding the date the plan’s initial application for SFA was filed;
(2) The plan’s participant census data required to be used in the plan’s initial application for
SFA under the interim final rule; and
23

(3) The plan’s non-SFA interest rate and SFA interest rate determined under § 4262.4(e)(1)
and (2).
The IFR filer submitting a revised application must otherwise submit all information required
under these general instructions (and Addendums A and D, as applicable). If a required
document has already been submitted with the initial or an earlier revised application, the IFR
filer does not need to re-submit that document, but the filer should identify in the SFA
Application Checklist that it was previously submitted and its submission date.
An IFR filer that has already received payment of SFA under the terms of the interim final rule
and wishes to submit a supplemented application must follow the instructions in Addendum C.
Finally, during the 120-day review period, PBGC may require a plan sponsor to file additional
information, including information to clarify or verify information provided in the plan’s
application. The plan sponsor must promptly file with PBGC any such information upon
request. If PBGC does not receive the requested information, the application may be considered
incomplete, and if an error or omission in an application requires a change to the amount of
special financial assistance requested, the application will be considered incomplete.

Paperwork Reduction Act Notice
This section provides information on the time and cost estimates for preparing and filing the
required application. If you have any comments concerning the accuracy of these estimates or
suggestions for making it simpler to submit the information, please send your comments to the
Pension Benefit Guaranty Corporation, Office of the General Counsel, 445 12th Street, SW,
Washington, DC 20024-2101.
Information filed with PBGC in an application for special financial assistance (SFA) is
confidential only to the extent provided in the Privacy Act. PBGC may, in its sole discretion,
post an application for SFA and any documents and information filed for the application on its
website at www.pbgc.gov, or otherwise publicly disclose the application, documents, and
information, except information that is confidential under the Privacy Act.
PBGC will share with the U.S. Department of Labor and the Treasury Department (collectively
the Agencies) a plan’s application, including any documents and information filed with PBGC,
to enable the Agencies to fulfill their responsibilities under ERISA.
This information collection is necessary for PBGC to properly administer the SFA program.
PBGC uses the information it receives in a plan’s application to determine, as required by
section 4262 of ERISA and 29 CFR part 4262, whether to approve or deny the requested
payment of SFA to the plan.

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PBGC estimates an average burden of 10 hours of Fund office time and $30,000 in contractor
costs per plan. These are estimates and the actual time and cost per plan will vary depending on
the circumstances of a given filing and the size of the plan.
This collection of information has been approved by the Office of Management and Budget
(OMB) under control number 1212-0074 (expires 01/31/2023). Under the Paperwork Reduction
Act, an agency may not conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB control number.

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