I am curious when and in what manner people are notifying participants of late quarterlies over 60 days late. I have never figured out when these are due to participants as the language in 101(d) is "...at such time and in such manner as the Secretary may prescribe."

I put em in a pile with all the suspension of benefits notices that nobody can find and wait for the Sec to prescribe.

It was MGB years back that confirmed (at least to my satisfaction) that no rules were ever issued by said Sec so why worry be happy.

We generally just put it into the SAR. It usually says something like ... here are the quarterly contribution requirements, this is when they were due, this is when we paid them...

I guess I thought that is what "everyone" was doing. Not sure if this still works under PPA.

Also, depending on the amount of the missed quarterly it could generate reportable events with the PBGC which has its own requirements.

I asked a "DB" person, and it apparently depends upon whether a PBGC notice is required re the variable rate premium. If no PBGC notice required, then a "reasonable" compliance timeframe, since they agreed with you that the DOL hasn't issued any guidance. If the PBGC notice (ERISA 4011??) is required, then this apparently requires the 60 day information, and is acceptable for satisfying the ERISA 101(d) notice requirment.

Thanks all.

Fortunately all my DB plans are under 500 lives and don't have enough funding to qualify for PBGC reporting, so at least I don't have to worry about that nonsense.