We have a situation where we prepare many PBGC filings for our clients. We currently prepare the filing, send it to the client for signature and delivery. Our clients are not prepared nor do they desire to fill out forms electronically or otherwise.

However, with the new electronic filing rules to take effect, I am not yet sure how this process can be handled.

Is anyone else in a situation like this thought of a technique to handle this?

I can't say that I'm fully up to speed, but the "Upload" approach (one of 3 alternatives) may work. Only one person (the Filing Coordinator - you?) needs to have an e-filing account with PBGC. The plan administrator and EA will certify on paper as needed; those certifications are retained in plan files in case of future audits; and the Filing Coordinator uploads the completed filing (certifying that the necessary PA and EA certifications have been completed). A variety of options are available for premium payment (online payment, paper check, etc.).

To use this approach you do need compatible software (hopefully not an issue).

Gary,

I have found the system to work fairly well so far. We have actually filed a few and have most of our clients signed up. They really do very little, in fact, probably less then then did with the paper.



All they need is an email account and access to the internet. It really isn't that bad once you have done it. The Filing Cordinator prepares all the forms, everyone else just clicks a box or two.

We have one client who refuses to give us an email account (he is simply anti-establishment) and I haven't figured out what to do with him, but once I told the others it was required, they all went along.

My experience has been nightmarish. I share Gary's concerns.

Effen, your company was named as filing coordinator? I had the impression that the client needed to have that role.

Yes, we are the Filing Cordinator for all our plans. I would agree that if you expect the client to be able to do this as the filing cordinator, you are in for some problems.

I understand what Effen is saying (and it's potential), however, I need to figure out how the process works. Is there a step by step procedural explanation at the PBGC web site?

For example do I prepare the form at the PBGC web site and then the client just edits their form at the web site (eg. signatures, etc.) and submits it?

Thanks.

Yes, you prepare the form on the PBGC web site. It looks very similar to the current paper form you work with now. Once the form is prepared, you "release" it to the next person who does their thing and "releases" it to the next person. As far as edits go, our forms are always perfect and never need editing

For example, theoretically, I, the actuary, prepare and sign the form, then "release" it to the HR person for his/her review. They get an email from MYPAA saying, "Effen has released the form to you". They follow the link and review the form. Once they are good with it, they release it to the CFO for signature. The CFO gets an email, follows the link, "signs" the form, the releases back to the HR person or to someone else to coordinate the premium payment.

I would recommend you do it first with a client you are very comfortable working with. Have them on the phone while you do it so you can find out what they are seeing on their screens and you can see what your screens say. That is what we did, and it's worked well so far.

Good Luck!

We are in the same boat--lots of small clients. Use the UPLOAD method! The client isn't involved except that they sign a form for your files and send a check to the PBGC. We have been doing it for over a year now. It is very easy. No complaints or questions from clients. Talk to Diane Morstein at PBGC if you need help.

One of the three options is to prepare the form as we did it before ..... using our 3rd party software (in our case, using Relius Government Forms). Everything can be done in a similar manner as before, except that when we are finished preparing and checking the filing on Relius, we simply upload it at that time to MyPAA and the filing is done. As the Enrolled Actuary, I have electronically signed the filing if an EA signature is required. I am also the Filing Coordinator for the plan. There can be a backup Filing Coordinator (recommended), either at your firm or the Plan Sponsor's.

All that remains after the upload is for us to send a paper form for the Plan Administrator to sign (he keeps the signed copy, and we ask him to send us a copy of his signed form ..... but it does not get sent to PBGC).

For paying the premium, there are several options, including payment online through MyPAA, or sending in a check with a voucher form.

That being said, our goal is to make this a "paperless" process, by using the second option where we prepare the filing in Relius, and get the Plan Sponsor's signature electronically online and encourage them to pay online.

For some reason I thought I needed to have a signed authorization from the employer to be the filing coordinator, but I don't see that in the on line instructions. Do I need that?