There is a strict prohibition against any audio or video recording of what goes on at these Enrolled Actuaries meetings and I am not entirely confident that it can even be repeated but here goes.
The rest of this day was spent going to sessions where regulators from the IRS and PBGC offered a combination of helpful links and dire warnings that should really be widely circulated were it not for the fear of the media distortion filter.
- IRS has these issue snapshots which are to help field agents but are made public.
- Most common error IRS is seeing on exam are cross-tested plans not providing gateway minimums.
- PBGC is stepping up with a voluntary missing participant program for plans it does not cover.
- PBGC looks for possible problems with single-employer plans based on public information (news media reports) and finds 300 annually of which 100 they review and about 5 get settlement agreements – listed here.
- PBGC lawyers are working on the church plan thing but my question about what their official position would be was not answered.
- PBGC has a multiemployer data book
- PBGC multiemployer program is headed for insolvency by 2025 and carving out the Teamsters plans (Central States, 560, 641) will not stave it off as they are only 60% of the problem with the other 40% big enough to sink the program. The charts (coming when I get to a scanner) predict that the PBGC multiemployer program will go under before Central States does so it is those other plans (Local 707 went under this year and more are predicted starting in 2020) that will do PBGC in.