(and an implied earlier due date for making 2024 contributions for some plans)
The Pension Benefit Guaranty Corporation (PBGC) is a government agency established by ERISA that covers certain defined benefit plans, including cash balance plans (footnote #1). It provides “insurance” by providing benefits if a plan terminates with insufficient assets to pay the promised benefits and the plan sponsor is financially unable (footnote #2) to contribute the shortfall.
Each year, plans covered by the PBGC must file a form called the “Comprehensive Premium Filing” (CPF) and pay a premium. Generally, the CPF is due on the 15th day of the tenth calendar month that begins on or after the first day of the plan year (footnote #3). For example, the filing due date for a plan with a 2025 calendar plan year would be October 15, 2025.
However, a provision in the Bipartisan Budget Act of 2015 provides that the CPF and premium payment for plan years beginning in 2025 are due one month earlier than usual. Therefore, plans with a 2025 calendar plan year will be required to file the form and pay the premium by September 15, 2025.
The accelerated due dates are applicable only to plan years beginning in 2025. Next year, the deadline reverts to the normal due date.
In some situations, the earlier 2025 CPF filing due date may require that 2024 plan contributions need to be deposited earlier than the usual deadline. If that situation applies to your plan, we will be in touch to provide further details.
Footnotes:
Plans covering only substantial owners, and plans maintained by a professional service employer which have never covered more than 25 active participants are exempt from PGBC coverage. For more information see
https://www.pbgc.gov/prac/other-guidance/insurance-coveragehttps://www.pbgc.gov/prac/terminations/distress-terminations
For certain special situations, a different due date might apply; e.g., new plans, terminating plans, or plans for which the plan year changed.