Justification for No Material or Nonsubstantive Change to Approved Collection
AGENCY: Pension Benefit Guaranty Corporation (PBGC)
TITLE: Annual Financial and Actuarial Information Reporting (29 CFR part 4010)
STATUS: OMB control number 1212‑0049; expires 02/28/2026
CONTACT: Karen Levin (202-229-3559)
The Pension Benefit Guaranty Corporation (PBGC) is making changes to the approved instructions, dated July 17, 2024, for plans to submit financial and actuarial information to PBGC, as a non-material/non-substantive change request under OMB Control Number 1212-0049, which is scheduled to expire on February 28, 2026.
Section 4010 of the Employee Retirement Income Security Act of 1974 (ERISA) and PBGC’s regulation on Annual Financial and Actuarial Information Reporting (29 CFR Part 4010) require a contributing sponsor of certain underfunded single-employer plans and members of the contributing sponsor’s controlled group to report identifying, financial and actuarial information to PBGC. In general, this reporting is required if one or more plans sponsored by a member of the controlled group has a funding target attainment percentage below 80%. The 4010 regulation specifies the items that filers must submit under section 4010 of ERISA, through PBGC’s e‑Filing Portal.
A section 4010 filing must include Schedule P plan actuarial information (see § 4010.8). On July 16, 2024, OMB approved PBGC’s request for a “No material or nonsubstantive change to a currently approved collection” which included updated Schedule P instructions. PBGC revised its filing instructions to implement its e-Filing Portal and now realizes that it inadvertently deleted an instruction that has been in the 4010 filing instructions for years (i.e., to require the filer to maintain a copy of the Schedule P which is manually signed by an enrolled actuary and noting that PBGC may request to see it at any time). PBGC is modifying the instructions to add this information back into the instructions. The changes to the instructions are shown below in red font.
Changes to the instructions for Schedule P, Section VII — Enrolled actuary certification
This certification is not done electronically. Rather, the enrolled actuary must manually sign a “form version” of the Schedule P information. A copy of the signed Schedule P must be kept in your records. PBGC may request to see a copy at any time.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Murphy Deborah |
| File Modified | 0000-00-00 |
| File Created | 2025-01-17 |