SFA Filing Instruc SFA Filing Instructions, Addendum A

OMB Control Number 1212-0074
Expires xx/xx/2027

MULTIEMPLOYER PROGRAM DIVISION
INSTRUCTIONS FOR FILING REQUIREMENTS FOR MULTIEMPLOYER PLANS
APPLYING FOR SPECIAL FINANCIAL ASSISTANCE
ADDENDUM A – SFA APPLICATION INSTRUCTIONS FOLLOWING CERTAIN
EVENTS
The plan sponsor of a plan that engaged in one or more events described in § 4262.4(f) of
PBGC’s SFA regulation, occurring during the period beginning on July 9, 2021 (the “applicable
date”) and ending on the plan’s SFA measurement date, is required to provide additional
information with its application for SFA as set forth in the following Addendum A to the general
instructions. Addendum A identifies and provides guidance on the additional information
required to be included in the application. All references to Sections A through Section E in this
Addendum A refer to the sections in the general instructions, and where applicable, to the
guidance for MPRA plans in Addendum D.
For purposes of these instructions, an “event” is any of the following that occurs during the
period beginning on the applicable date and ending on the plan’s SFA measurement date:
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Transfer of assets or liabilities (including a spinoff) as defined in § 4262.4(f)(2).
This does not include a merger.
An amendment that increases accrued or projected benefits, as described in
§ 4262.4(f)(3).
A reduction in the contribution rate used to determine contributions, as described
in § 4262.4(f)(4). If there is a reduction in benefit accruals associated with the
contribution rate reduction, under § 4262.4(f)(4), that plan change is considered
part of this event.

Much of the additional information to be provided is the same for all events described in
§ 4262.4(f)(2) through (f)(4).
For plans that experience a merger event, as described in § 4262.4(f)(1)(ii), during the period
beginning on the applicable date and ending on the SFA measurement date, more extensive
information is required regarding: (1) each plan that was involved in the merger and (2) the
merged plan. The term “merger event” is referred to separately in these instructions and is not
included within the term “event.” 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, which must follow the directives for
revised applications in the general instructions.
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The requirements below apply to any event or a merger event:
SECTION A – Plan identifying information. For Section A, Item (6), provide the amount of
SFA requested, reflecting the provisions of § 4262.4 including § 4262.4(f).
SECTION B – Plan documents. All information to be provided with respect to Section B
should reflect the event or merger event.
Following a merger event, information provided for Items (1) through (9) should include
information for both the merged plan that is applying for SFA and for each plan that was
involved in the merger. For example, if Plan A merges into Plan B, then include Items (1)
through (9) for Plan A and Plan B.
SECTION C – Plan data. For all items in section C, prepare all requested information
reflecting the event or merger event and a version of Section C, Item (4) (SFA Determination,
Template 4A) that shows the determination of the SFA amount for the plan as if the event or the
merger event had not occurred. In addition, MPRA plans for which the requested amount of
SFA is determined under the present value method in § 4262.4(a)(2)(ii), must provide SFA
Determination Template 4B as described in Addendum D.
For a plan that experiences a merger event, information provided for Section C, Items (1)
through (3) should include information for both the merged plan and for each plan involved in
the merger. For example, if Plan A merged into Plan B, then include additional information for
Section C, Items (1) through (3) for both Plan A and Plan B. When the plan provides the
additional information for Section C, Item (4) that shows the determination of the SFA amount
as if the merger event had not occurred, the plan should show the determination of the SFA
amount for the merged plan and for each plan involved in the merger, determined as if they were
still separate plans (in the format of Template 4A, and, where applicable, Template 4B). For
example, if Plan A merged into Plan B, then include Section C, Item (4) for Plan A and for Plan
B as if they were separate plans.
SECTION D – Plan statements. Information provided for Section D must reflect the event or
merger event. The filer must upload a separate document to the e-Filing Portal as document type
“Special Financial Assistance Application” that provides the following additional information:
For section D, Item (3) (SFA Eligibility), provide information reflecting each event and provide
information that demonstrates that the plan is eligible for SFA where eligibility is determined as
if the event had not occurred. Following a merger event, provide additional demonstrations of
the SFA eligibility (or lack thereof) for the merged plan and for each plan involved in the merger
determined as if they were still separate plans.
Provide a narrative description of each event and merger event, including relevant supporting
documents such as plan amendments, collective bargaining agreements, actuarial certifications
related to a transfer or merger, or other relevant materials. Provide identifying information for
all plans involved in a transfer of assets or liabilities (including a spinoff) described in
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§ 4262.4(f)(2) or a merger event described in § 4262.4(f)(1)(ii), including plan name, EIN and
plan number, and the date of the transfer or merger.
The narrative description should identify both the amount of requested SFA that reflects the
event or merger event and the amount of SFA determined as if the event or merger event had not
occurred. It should also confirm that the requested SFA provided in Section A, Item (6) is not
greater than the amount that would have been determined if the event had not occurred, unless
the event is a contribution rate reduction and such event lessens the risk of loss to plan
participants and beneficiaries. Following a merger event, the amount of SFA determined as if
the merger event had not occurred is the sum of the amounts that would be determined for the
merged plan and each plan involved in the merger as if they were still separate plans.
Following an event due to a contribution rate reduction, if the amount of requested SFA is not
limited to the amount of SFA determined as if the event had not occurred, provide a detailed
demonstration that shows that the event lessens the risk of loss to plan participants and
beneficiaries. Also identify all assumptions used, supporting rationale for the assumptions, and
other relevant information.
SECTION E – Checklist and certifications. All information to be provided for Section E
should reflect, as applicable, the event or merger event. The filer should also upload additional
information as follows:
For section E, Item (2) (SFA Eligibility Certification and Supporting Information for Critical and
Declining Plan) and Section E, Item (3) (SFA Eligibility Certification and Supporting
Information for Critical Plan), the plan should provide the plan actuary’s certification reflecting
the event or merger event, and an additional certification of the plan’s SFA eligibility determined
as if they had not occurred. For a merger event, provide additional certifications of the SFA
eligibility for the merged plan and for each plan involved in the merger as if they were still
separate plans.
For section E, Item (5) (SFA Amount Certification), the plan must provide the plan actuary’s
certification reflecting the events and an additional certification that is determined as if the
events had not occurred. For a merger event, provide additional certifications of the SFA
amount determined for the merged plan and for each plan merged into this plan (each of these
determined as if they were still separate plans). Each of these certifications should clearly
identify all assumptions and methods used, sources of participant data and census data, SFA
measurement date, and other relevant information.
For an event due to a contribution rate reduction where the plan provides a demonstration that
the event lessens the risk of loss to plan participants and beneficiaries, the plan should provide an
additional certification from the plan’s enrolled actuary (or if appropriate, from the plan sponsor)
regarding the demonstration provided to support a finding that the event lessens the risk of loss
to plan participants and beneficiaries. This certification must identify all assumptions and
methods used, sources of participant data and census data, SFA measurement date, and other
relevant information.
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