sfa-filing-instructions

OMB Control Number 1212-0074
Expires XX/XX/202X
Updated 11/01/2023

MULTIEMPLOYER PROGRAM DIVISION
GENERAL INSTRUCTIONS FOR MULTIEMPLOYER PLANS APPLYING FOR
SPECIAL FINANCIAL ASSISTANCE

General Information
These general instructions are guidance setting forth the requirements for a multiemployer plan
filing an application for special financial assistance (SFA) with PBGC. This guidance refers to
section 4262 of the Employee Retirement Income Security Act of 1974 (ERISA) and PBGC’s
SFA regulation (29 CFR part 4262).
Section 9704 of the American Rescue Plan (ARP) Act of 2021 (P.L. 117-2) added section 4262 to
ERISA, which authorizes PBGC to provide SFA to eligible multiemployer plans. Certain
multiemployer plans are eligible to apply for SFA if they are in critical and declining or critical
status; were approved to suspend benefits under the Multiemployer Pension Reform Act of 2014
as of March 11, 2021; or became insolvent after December 16, 2014, and have remained insolvent
and have not terminated as of March 11, 2021.
On July 8, 2022, PBGC published a final rule that made changes to PBGC’s SFA regulation and
replaced an interim final rule issued on July 9, 2021. The final rule became effective on August 8,
2022.
The SFA regulation sets forth the requirements for SFA applications and related restrictions and
conditions. These general instructions, along with the corresponding templates, addendums, and
SFA assumptions guidance, provide additional guidance to multiemployer plans on how to
prepare and file the required SFA application information.
The amount of SFA requested is determined as of the plan’s “SFA measurement date.” Except for
a plan that filed its initial SFA application before August 8, 2022, when the interim final rule was
in effect, a plan’s SFA measurement date is defined in § 4262.2 of PBGC’s SFA regulation as the
last day of the third calendar month immediately preceding the date the plan’s initial application is
filed. For example, if the plan’s initial application was filed on March 15, 2023, its SFA
measurement date would be December 31, 2022; if the plan’s application was filed on July 1,
2023, its SFA measurement date would be April 30, 2023. For a plan that submitted its initial
SFA application under the interim final rule before August 8, 2022, its SFA measurement date is
the last day of the calendar quarter immediately preceding the date the plan’s initial application
was filed.
Addendum A provides instructions on the additional information required for a plan that engaged
in certain events between July 9, 2021, and its “SFA measurement date.”
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Addendum B provides instructions for the notice of reinstatement of benefits required to be issued
by a plan sponsor of a plan that suspended benefits.
Addendum C provides instructions for filing a supplemented application for plans that received
payment of SFA under the terms of the interim final rule and seek (1) to apply for additional SFA
or (2) subject themselves, without applying for additional SFA, to the conditions of the final rule.
Addendum D provides instructions on additional information to be filed for MPRA plans (MPRA
plans are defined in § 4262.4(a)(3) of PBGC’s SFA regulation).
Pre-application consultations and questions
A plan sponsor may request an informal pre-application consultation to discuss a plan’s potential
application for SFA. At a pre-application consultation, PBGC staff members cannot offer binding
decisions on such topics as a plan’s eligibility for SFA or the amount of SFA to which it might be
entitled. However, staff members can provide overviews of the SFA program and the application
process and offer helpful tips. To request a pre-application consultation, send an email to the
Multiemployer Program Division mailbox at multiemployerprogram@pbgc.gov, with the subject
“Special Financial Assistance Consultation Request from (Plan Name).” You may send other
questions about the SFA program to this email address as well, with the subject “Special Financial
Assistance Question from (Plan Name).”

Filing an Application for Special Financial Assistance
Where to file an application
An application, with the exception of a lock-in application, must be submitted to PBGC
electronically through PBGC’s e-Filing Portal, (https://efilingportal.pbgc.gov/site/). After logging
into the e-Filing Portal, go to the Multiemployer Events section and click “Create New ME
Filing.” Under “Select a filing type,” select “Application for Financial Assistance – Special.”
Note: revised and supplemented applications must be submitted by selecting “Create New ME
Filing.”
A lock-in application under § 4262.10(g) is treated as a plan’s initial application and locks in the
plan’s SFA measurement date, participant census data, non-SFA interest rate, and SFA interest
rate. It is submitted by email to multiemployerprogram@pbgc.gov in accordance with the lock-in
application instructions.
Note: In the case of a plan applying for priority consideration, PBGC will transmit the plan’s
application to the U.S. Department of the Treasury (Treasury Department). See section
432(k)(1)(D) of the Internal Revenue Code and guidance issued by the Treasury Department and
Internal Revenue Service (IRS) (Notice 2021-38) for further information.

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When to file an application
An initial application must be filed no later than December 31, 2025, and a revised application
must be filed no later than December 31, 2026. See § 4262.10(d) of PBGC’s SFA regulation.
Plans in priority groups will be given the opportunity to file before March 11, 2023. See
PBGC’s website, www.pbgc.gov, for updated information on when plans in various priority
groups and plans not in any priority group may apply.
Note: If you go to the e-Filing Portal and do not see “Application for Financial Assistance –
Special” under the “Select a Filing Type,” then the e-Filing Portal is temporarily closed and
PBGC is not accepting applications (other than lock-in applications), unless the plan is eligible to
make an emergency filing under § 4262.10(f). PBGC’s website, www.pbgc.gov, will be updated
when the e-Filing Portal reopens for applications. PBGC maintains information on its website to
inform prospective applicants about the current status of the e-Filing portal, as well as to provide
advance notice of when PBGC expects to open or temporarily close the e-Filing Portal.
In the event the e-Filing Portal is temporarily closed, the emergency filing process allows PBGC
to accept a priority application from a plan that is insolvent or expected to become insolvent under
section 4245(a) of ERISA within 1 year of filing an SFA application, or from a plan that has
implemented a suspension of benefits under section 305(e)(9) of ERISA as of March 11, 2021.
See § 4262.10(f) of PBGC’s SFA regulation. PBGC will accept emergency filings from these
plans during periods when PBGC would not otherwise accept such applications. Before
submitting an application under the emergency filing process, a filer must send an email to the
Multiemployer Program Division mailbox at multiemployerprogram@pbgc.gov, and include as
the subject “Emergency Filing, Special Financial Assistance Application of (Plan Name).” In the
email, the filer must substantiate the claim of emergency status. Also in the email, the filer must
provide a contact person’s name, email address, and phone number. The contact person will
receive further instructions from PBGC as to how to submit the plan’s emergency application.
Information required for an application
The SFA application has five sections (Section A through Section E), which are described below.
Section A – Plan identifying information. This section requires the filer (e.g., accountant, actuary,
attorney, plan administrator, trustee) to input basic identifying plan information into the e-Filing
Portal.
Sections B through E. The filer must upload all required application files to the Documents page
of the e-Filing Portal and identify each document type from the dropdown list. The Application
for Approval of Special Financial Assistance Checklist (“SFA Application Checklist”) identifies
the specific document type to be selected for each item.
Section B – Plan documents. This section requires information that generally is readily available
to the plan sponsor, such as plan documents and actuarial valuation reports. It also requires an
enrollment form for the transfer of funds.

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Section C – Plan data. This section requires information that the filer must provide in Excel
compatible files. Links to the format and templates that may be used can be found throughout
these instructions.
Section D – Plan statements. This section requires information that the filer must provide in a
single, written document. On the SFA Application Checklist (Section E, Item (1)), the filer must
identify the page numbers of this written document that are responsive to each required item.
Section E – Checklist, certifications, and SFA-related plan amendments. This section requires the
filer to complete the SFA Application Checklist and identifies the various required certifications,
plan amendments related to SFA, and other information.
Note: If required information was already filed: (1) through PBGC’s e-Filing Portal; or (2)
through any means for an insolvent plan, a plan that has received a partition, or a plan that
submitted an emergency filing, the filer may either upload the information with the SFA
application or include a statement on the SFA Application Checklist that indicates the date
on which and the submission with which the required information was previously filed.
If, while the application is pending, the plan sponsor becomes aware of information that
is no longer accurate or that has been omitted from the application, it must notify PBGC.
See § 4262.6(e)(3) of PBGC’s SFA regulation.
SECTION A – Plan identifying information. The filer inputs the following information into
the e-Filing Portal.
(1) Plan name.
(2) Employer identification number (EIN).
(3) Plan number (PN).
(4) Notice filer name. Name of the individual authorized to file the SFA application.
(5) Role of filer. Relation of the individual filing the SFA application to the plan (e.g.,
accountant, actuary, attorney, plan administrator, trustee).
(6) Total amount requested. Amount of total SFA requested under § 4262.4(a)(1) or
§ 4262.4(a)(2) of PBGC’s SFA regulation. This figure should match the amount reported
in Section E, Item (5).
SECTION B – Plan documents. The filer uploads the following documents to the e-Filing
Portal, using where applicable the required filenames identified on the SFA Application Checklist.
(1) Plan documentation.
a. Most recent plan document or restatement of the plan document and all
amendments adopted since the last restatement (if any).
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b. Most recent trust agreement or restatement of the trust agreement and all
amendments adopted since the last restatement (if any).
c. Most recent IRS determination letter.
(2) Actuarial valuation reports. Actuarial valuation report for the 2018 plan year and each
subsequent actuarial valuation report completed before the filing date of the initial
application. Provide each report as a separate document.
(3) Rehabilitation plan or funding improvement plan. Most recent rehabilitation plan or, if
applicable, funding improvement plan, including all subsequent amendments and
updates, and the percentage of total contributions received under each schedule of the
rehabilitation plan or funding improvement plan for the most recent plan year available.
If the most recent rehabilitation plan does not include historical documentation of
rehabilitation plan changes (if any) that occurred in calendar year 2020 and later, provide
these details in a clearly identified additional document.
Provide each rehabilitation or funding improvement plan as a separate document.
(4) Form 5500. Most recently filed (as of the filing date of the initial application) Form 5500
and all schedules and attachments, including the audited financial statements. Provide as
a single document.
(5) Zone certifications. Plan actuary’s certification of plan status for the 2018 plan year
and each subsequent annual certification completed before the filing date of the initial
application, with documentation supporting each actuarial certification of plan status.
The documentation supporting each actuarial certification must clearly identify all
assumptions used, including the interest rate used for funding standard account purposes;
such identification may be provided in an addendum (in which case, addendums are only
required for the most recent actuarial certification of plan status completed before
January 1, 2021, and all subsequent annual certifications) or by reference to other
submitted materials such as an actuarial valuation report. Separately identify as
“additional information” all information included with the zone certification to comply
with this Section B, Item (5) that was not part of the original zone certification. Provide
each zone certification (including its identified additional information) as a single
document, separately for each plan year.
Documentation supporting a certification of critical and declining status must include
a plan-year-by-plan-year projection demonstrating the plan year that the plan is
projected to become insolvent. Provide the required plan-year-by-plan-year
projection for each certification separately and identify the fair market value of plan
assets as of the beginning and end of each plan year within the relevant period
described in section 305(b)(6) of ERISA. Also, identify the following cash-flow
items for each of those years:
a. Contributions.
b. Withdrawal liability payments.
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c.
d.
e.
f.

Benefit payments.
Administrative expenses.
Amount of net investment returns.
Investment return assumption.

(6) Account statements. Most recent statement for each of the plan’s cash and investment
accounts.
(7) Plan’s financial statement. Most recent plan financial statement (audited, or unaudited if
audited is not available).
(8) Withdrawal liability documentation. All of the plan’s written policies and procedures
governing determination, assessment, collection, settlement, and payment of withdrawal
liability. Provide all items as a single document.
(9) Death Audit and Census Data.
a. Documentation of a death audit to identify deceased participants that was
completed on the census data used for SFA purposes, including identification of
the service provider conducting the audit, date performed, date of participant
census data, the participant counts (provided separately for current retirees and
beneficiaries, current terminated vested participants not yet in pay status, and
current active participants) run through the death audit, and a copy of the results
of the audit provided to the plan administrator by the service provider. If the
death audit identifies known deaths that occurred before the date of the census
data used for SFA purposes, and the plan does not have information that
conclusively demonstrates the participant is alive, such as a record of a call the
participant had with the plan after the purported date of death, for these known
deaths, provide a statement certifying these deaths were reflected for SFA
calculation purposes. Deaths that occur after the census date should not be
reflected (except as noted in Section III.F of PBGC’s SFA assumptions
guidance). If personally identifiable information is included in the death audit
report, the filer must redact it before submission to PBGC.
i.

Reflecting known deaths that occurred before the date of the
participant census data. The projected benefits and projected
headcounts used in the determination of the SFA amount must
reflect deaths that occurred before the census date. If the plan
records reflect the marital status 1 of a deceased participant, that
information should be used in the projections. Otherwise, apply the
plan’s assumptions for percent married and spousal gender/date of
birth to project any survivor benefits available under the plan.

If the plan provides survivor benefits for non-spouse beneficiaries, treat any such beneficiaries in the same
manner as spouses as described in these instructions.

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b. Complete census data of all participants in all categories that were included in the
SFA projections. Provide this data in Excel, or an Excel-compatible format, and
include only name, participant status (e.g., active, retiree, beneficiary, terminated
vested), and Social Security Number. The census data file submitted in response
to this request must be the same as the file used to determine the SFA amount.
PBGC will conduct an independent death audit on this file and, if deaths are
identified that occurred before the date of the census data used for SFA purposes,
provide instructions, as needed, for the plan to reflect the results of the audit for
SFA calculation purposes.
c. For a plan that submits its census data early in accordance with this paragraph, a
description of how the results of PBGC’s independent death audit are reflected
for SFA calculation purposes. A plan that has filed a lock-in application may
submit the plan’s census data file and request that PBGC conduct the independent
death audit before the plan submits its full revised application. To request the
independent death audit before filing a full revised (not lock-in) application,
submit the data file and the date of the census data through PBGC’s secure file
transfer system, Leapfile. First send an email to sfa@pbgc.gov to request a
recipient email address. The email address provided will be that of a PBGC staff
member in the Multiemployer Program Division, e.g, a “[last name].[first
name]@pbgc.gov” email address. Go to http://pbgc.leapfile.com, click on
“Secure Upload” and then enter the email addresses provided by PBGC as the
recipient email address and upload the file(s) for secure transmission. Include as
the subject “Submission of Census Data for (Plan Name),” and as the memo
“(Plan Name) census data dated (date of census data) through Leapfile for
independent audit by PBGC.” PBGC will provide the applicant with a report
identifying participants in the data file that match known deaths. This report does
not relieve the plan from furnishing the death audit required by Item (9)(a) when
it files its full revised (not lock-in) application.
(10) Automated Clearing House (ACH) Vendor/Miscellaneous Payment Enrollment Form and
required notarized bank letter. This ACH form is used to enable the plan to receive
electronic transfer of funds, if the SFA application is approved. When transferring funds,
PBGC will use ACH process or Fedwire process (preferred) for amounts up to $100
million (if further information is required for a sub account i.e., “further credit to” a
Fedwire is required), and only Fedwire process for amounts over $100 million. If the
plan is requesting SFA in an amount that is over $100 million, then the filer must confirm
the bank’s routing number listed on the ACH form for a Fedwire transfer and any other
information necessary for the transfer. Filers are encouraged to contact the Treasury
Offset Program (TOP) call center at 800-304-3107 (800-877-8339 for TTY/TDD help) to
determine if there are any outstanding debts associated with the plan’s EIN that must be
resolved to avoid possible delays in the transfer of funds.
In addition to the plan’s completed, signed ACH payment form, the plan’s bank official
must include a notarized bank letter on bank letterhead with signature of the bank official.
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The banking information in the ACH form must match the notarized bank letter by the bank
official. The notarized letter should contain the following information:
•
•
•
•
•
•
•

Name and email address of a point of contact at the bank (used for PBGC to confirm
receipt of funds);
Depositor Account Title;
Name on bank account; i.e., no numerical characters
Bank routing number;
Bank account number;
Any special instructions such as “for further credit instructions;” and
Indicate if the banking instructions provided can accept ACH, Fedwire, or both
payment types.

If a plan closes the bank account that it listed on this form before PBGC transfers the SFA,
then the plan must notify PBGC immediately and submit an updated form with notarization.
SECTION C – Plan data. The filer completes and uploads an Excel compatible file to the eFiling Portal for each item below, using, where applicable, the required filenames identified on the
SFA Application Checklist. The filer may use the templates specified with each item.
(1) Form 5500 projection. Template 1: For the 2018 plan year until the most recent plan year
for which the Form 5500 is required to be filed by the filing date of the initial application,
the projection of expected benefit payments as required to be attached to the Form 5500
Schedule MB if the response to line 8b(1) of the Form 5500 Schedule MB should be
“Yes.”
(2) Contributing employers. Template 2: If the plan has 10,000 or more participants, as
required to be entered on line 6f of the plan’s most recently filed Form 5500 (by the filing
date of the initial application), a listing of the 15 largest contributing employers (the
employers with the largest contribution amounts) and the amounts of contributions paid
by each of these employers during the most recently completed plan year (before the
filing date of the initial application). For example, if a calendar year plan filed an
application on April 1, 2023, the plan would look to line 6f of the 2021 Form 5500 filed
in 2022. If line 6f of the 2021 Form 5500 showed 10,000 or more participants, the plan
must list the 15 contributing employers with the largest contributions and the amounts of
the contributions made by each of those employers during 2022, without regard to
whether a contribution was made on account of a year other than 2022. Alternatively, the
plan may choose to provide the listing of the 15 largest contributing employers and the
amounts of contributions paid by each of these employers on account of the most recently
completed plan year. Identify the basis (cash or accrual) used to report the employer
contributions. If the plan is required to provide this information, it is required for the 15
largest contributing employers even if the employer’s contribution is less than 5% of total
contributions.

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(3) Historical plan information. Template 3: Historical plan information for the 2010 plan
year through the plan year immediately preceding the date the plan’s initial application
was filed that separately identifies: total contributions, total contribution base units
(including identification of the unit used (i.e., hourly, weekly)), average contribution
rates, and number of active participants at the beginning of each plan year. Also, show
separately for each of the plan years in the same period all other sources of
noninvestment income, including, if applicable, withdrawal liability payments collected,
reciprocity contributions (if applicable), additional contributions pursuant to the
rehabilitation plan (if applicable), and other identifiable contribution streams.
(4) SFA determination. Template 4A: The calculation of the amount of SFA differs for
different eligible plans, as follows:
•

Plans that are not MPRA plans – “basic method.” For a plan that does not meet the
definition of a “MPRA plan” under § 4262.4(a)(3) of PBGC’s SFA regulation, the amount
of SFA is determined under the “basic method” described in § 4262.4(a)(1) of PBGC’s
SFA regulation.

•

MPRA plans. For a plan that meets the definition of a “MPRA plan” under § 4262.4(a)(3)
of PBGC’s SFA regulation, the amount of SFA determined under § 4262.4(a)(2) of
PBGC’s SFA regulation is the greatest of the three amounts calculated using the “basic
method” determined under § 4262.4(a)(1) of PBGC’s SFA regulation, the “increasing
assets method” determined under § 4262.4(a)(2)(i), and the “present value method”
determined under § 4262.4(a)(2)(ii).
All plans must provide the information described below for the “basic method” and may
use Template 4A. MPRA plans must provide additional information, including the amount
of SFA calculated using the “increasing assets method,” using the format of Template 4A,
as described in Addendum D. A MPRA plan that calculates the greatest amount of SFA
using the “present value method” must provide additional information using the format of
Template 4B, as described in Addendum D.
Provide information used to determine the amount of SFA for the plan using the “basic
method” described in § 4262.4(a)(1) of PBGC’s SFA regulation based on a deterministic
projection and using the actuarial assumptions as described in § 4262.4(e) of PBGC’s SFA
regulation. The information to be provided is:
a. The amount of SFA calculated using the “basic method,” determined as a lump sum as
of the SFA measurement date.
b. Non-SFA interest rate required under § 4262.4(e)(1) of PBGC’s SFA regulation,
including supporting details on how it was determined.
c. SFA interest rate required under § 4262.4(e)(2) of PBGC’s SFA regulation, including
supporting details on how it was determined.
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d. Fair market value of assets as of the SFA measurement date. This amount should
include any assets at the SFA measurement date attributable to financial assistance
received by the plan under section 4261 of ERISA on or before the SFA measurement
date, but it should not reflect a payable for amounts owed to PBGC for any amounts of
such financial assistance received by the plan.
e. For each plan year in the period beginning on the SFA measurement date and ending
on the last day of the last plan year ending in 2051 (the “SFA coverage period”):
i. Separately identify the projected amount of contributions, projected
withdrawal liability payments reflecting a reasonable allowance for
amounts considered uncollectible, and other payments expected to be made
to the plan (excluding the amount of financial assistance under section 4261
of ERISA and SFA to be received by the plan).
ii. Identify the benefit payments described in § 4262.4(b)(1) (including any
benefits that were restored under 26 CFR 1.432(e)(9)-(1)(e)(3) and
excluding the make-up payments in Item (4)e.iii. below), separately for
current retirees and beneficiaries, current terminated vested participants not
yet in pay status, current active participants, and new entrants; and total
benefit payments paid and expected to be paid from projected SFA assets
separately from total benefit payments paid and expected to be paid from
non-SFA assets after the projected SFA assets are fully exhausted.
Demographic actuarial assumptions (death, withdrawal, retirement,
disability) should be applied between the census date and the SFA
measurement date in the determination of benefit payments.
iii. Separately identify the make-up payments described in § 4262.4(b)(1)
attributable to the reinstatement of benefits under § 4262.15 that were
previously suspended through the SFA measurement date.
The following example provides additional information about how to
determine the amounts to be provided in Section C, Items (4)e.ii. and
(4)e.iii. for reinstatement of benefits previously suspended under sections
305(e)(9) or 4245(a) of ERISA.
Example – Joe is a retiree who was receiving a monthly benefit of $2,000
per month payable as a straight life annuity on the first of each month until
a benefit suspension took effect on 1/1/2019. Starting on 1/1/2019, his
benefit was reduced to $1,000 per month. The SFA measurement date is
12/31/2021, which means that, as of the SFA measurement date, 36 months
of benefit payments have been suspended (from 1/1/2019 through
12/31/2021).
The plan decides to restore benefits at the latest possible date, so the
monthly benefit paid to Joe will not increase to the original $2,000 per
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month until the first of the month in which the SFA is paid to the plan (see
§ 4262.15(a)(1)). Also, the “make-up” payment will cover the period from
1/1/2019 through the month preceding the month in which the SFA is paid.
However, for purposes of determining the SFA amount, only, under
§ 4262.4, calculations are performed as if the projected benefit begins
the day after the SFA measurement date as shown below:
Scenario A – Plan elects to pay the make-up payment as a single lump sum
Step 1 – The projected benefits to be provided in Section C, Item (4)e.ii. will
reflect $2,000 per month payable to Joe starting on 1/1/2022 for the
remainder of his life.
Step 2 – The benefit payment to be provided in Section C, Item (4)e.iii. will
be $36,000, the make-up payment assumed to be paid as of the SFA
measurement date of 12/31/2021.
Scenario B – Plan elects to pay the make-up payment in equal monthly
installments over 5 years
Step 1 – The projected benefits provided in Section C, Item (4)e.ii. will
reflect $2,000 per month payable to Joe starting on 1/1/2022 for the
remainder of his life.
Step 2 – The make-up payment is paid in 60 equal monthly installments of
$600 ($36,000 divided by 60). The benefits to be provided in Section C,
Item (4)e.iii. will reflect $600 per month payable to Joe (or his designated
beneficiary) starting on 1/1/2022 for 60 months.
iv. Separately identify administrative expenses paid and expected to be paid
(excluding the amount owed PBGC under section 4261 of ERISA) for
premiums to PBGC and for all other administrative expenses; and identify
total administrative expenses paid and expected to be paid from projected
SFA assets separately from total administrative expenses paid and expected
to be paid from non-SFA assets after the projected SFA assets are fully
exhausted.
v. Provide the projected total participant count at the beginning of each plan
year.
vi. Provide the projected investment income earned by assets not attributable to
SFA based on the non-SFA interest rate in Section C, Item (4)b. and the
projected fair market value of non-SFA assets at the end of each plan year.
vii. Provide the projected investment income earned by assets attributable to
SFA based on the SFA interest rate in Section C, Item (4)c. (excluding
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investment returns for the plan year in which the sum of the annual
projected benefit payments and administrative expenses for the year
exceeds the beginning-of-year projected SFA assets) and the projected fair
market value of SFA assets at the end of each plan year.
f. The projected SFA exhaustion year. This is the first day of the plan year in which the
sum of annual projected benefit payments and administrative expenses for the year
exceeds the beginning-of-year projected SFA assets.
(5) Baseline details. Template 5A: This Template 5A is required (except as noted in the
next paragraph) for plans that are not MPRA plans. See Addendum D for separate
instructions for Baseline details to be submitted for MPRA plans.
This item is not required if all assumptions and methods used to determine the requested
SFA amount are identical to those used in the most recent actuarial certification of plan
status completed before January 1, 2021 (“pre-2021 certification of plan status”), except
the non-SFA and SFA interest rates, and except any assumptions that were changed in
accordance with Section III, Acceptable Assumption Changes, in PBGC’s SFA
assumptions guidance (other than the acceptable assumption change for “missing”
terminated vested participants described in Section III.F of PBGC’s SFA assumptions
guidance).
Provide a separate deterministic projection (“Baseline”) in the same format as Section C,
Item (4) that shows the amount of SFA using the basic method (§ 4262.4(a)(1) of
PBGC’s SFA regulation) that would be determined if all underlying assumptions and
methods used in the projection were the same as those used in the pre-2021 certification
of plan status, except the plan’s non-SFA interest rate and SFA interest rate, which
should instead be the same as used in Section C, Item (4). For purposes of Section C,
Item (5), any assumption change made in accordance with Section III, Acceptable
Assumption Changes, in PBGC’s SFA assumptions guidance should be reflected in this
Baseline calculation of the SFA amount and supporting projection information, except
that an assumption change for “missing” terminated vested participants described in
Section III.F of PBGC’s SFA assumptions guidance should not be reflected in the
Baseline projections. Assumption changes made in accordance with Section IV,
Generally Accepted Assumption Changes, in PBGC’s SFA assumptions guidance should
not be reflected in this Baseline calculation. See the example below.
Example – Plan A applies for SFA in 2025 with an SFA measurement date of
12/31/2024. Plan A’s actuary prepared an actuarial certification of plan status on
3/15/2020 for the plan year beginning 1/1/2020. This is the most recent certification of
plan status before 1/1/2021. In that certification, the plan’s status is critical and
declining, and the plan is projected to become insolvent within 8 years. When
calculating the amount of requested SFA, the plan actuary uses the same assumptions
that were used to prepare the actuarial certification of plan status on 3/15/2020 except
for the following changes in assumptions:
12

•

The funding standard account interest rate used in the pre-2021 certification is
6.00%. Assume that the applicable interest rate limit in § 4262.4(e)(1)(ii) of
PBGC’s SFA regulation is 5.50%, and the applicable interest rate limit in
§ 4262.4(e)(2)(ii) of PBGC’s SFA regulation is 3.50%. The SFA amount will be
calculated using a non-SFA interest rate of 5.50% and an SFA interest rate of
3.50%

•

The mortality table used in the pre-2021 certification is the RP-2000 Mortality
Table with projected improvements through 2025 using Scale AA. The plan
actuary determines the mortality assumption used in this certification is no longer
reasonable and proposes changing to the Pri-2012 amount-weighted Blue Collar
table (Pri-2012(BC)) with projected improvements based on a mortality
improvement scale published in 2024 by the Retirement Plans Experience
Committee of the Society of Actuaries.

•

Since the pre-2021 certification projected the plan to be insolvent within 8 years,
the plan actuary must adopt assumptions to project administrative expenses and
CBUs to the end of the SFA coverage period. The plan actuary adopts the
assumptions for administrative expenses in Section III, Acceptable Assumption
Changes, in PBGC’s SFA assumptions guidance to project administrative
expenses through 2051. The plan actuary adopts a CBU assumption based on
information provided by the plan sponsor. The CBU assumption meets the
criteria in Section IV.A, Generally Acceptable Assumption Changes, Proposed
Change to CBU Assumption, in PBGC’s SFA assumptions guidance, but the
changed CBU assumption does not meet the criteria in Section III, Acceptable
Assumption Changes, in PBGC’s SFA assumptions guidance.

•

Since the pre-2021 certification projected the plan to be insolvent within 8 years,
the plan actuary only had an assumption for withdrawal liability payments during
those 8 years, and must extend the assumption to project withdrawal liability
payments expected to be received by the plan to the end of the SFA coverage
period. With input from the plan sponsor, the plan actuary develops a 30-year
projection reflecting a reasonable allowance for amounts considered
uncollectible.

•

The plan actuary determines that the assumed retirement rates and payment form
assumptions used in the pre-2021 certification are no longer reasonable and
makes changes to each of these assumptions based on an analysis of plan
experience and reasonable expectations.

The projections to be provided for Section C, Item (5) – Baseline – should reflect the following
assumptions:
•

Non-SFA interest rate: 5.50%
13

•

SFA interest rate: 3.50%

•

Mortality: Pri-2012(BC) with mortality improvement scale published in 2024 by
the Retirement Plans Experience Committee of the Society of Actuaries. This
assumption change is included in the Baseline because it is in Section III,
Acceptable Assumption Changes, in PBGC’s SFA assumptions guidance.

•

Extended CBU assumption: The CBU assumption to be shown in the Baseline
projections should reflect the “extension” of the CBU assumption that is
consistent with Paragraph A, “Adoption of assumptions not previously factored
into pre-2021 certification of plan status,” of Section III, Acceptable Assumption
Changes, in PBGC’s SFA assumptions guidance.

•

Extended administrative expense assumption: This assumption change is included
in the Baseline because it is in Section III, Acceptable Assumption Changes, in
PBGC’s SFA assumptions guidance.

•

All other assumptions used in the projections should be the same assumptions
used in the pre-2021 certification.

All other assumption changes that are reflected in the calculation of the SFA amount in
Section C, Item (4) (e.g., change in CBU assumptions that is different than the “acceptable”
extension, new withdrawal liability payments, retirement rates and assumed payment forms)
should not be included in the Baseline information.
(6) Reconciliation details. Template 6A: This Template 6A is required (except as noted in
the next paragraph) for plans that are not MPRA plans. See Addendum D for separate
instructions for Reconciliation details to be submitted for MPRA plans.
This item is not required if all assumptions and methods used to determine the requested
SFA amount are identical to those used in the pre-2021 certification of plan status,
except the non-SFA and SFA interest rates, and except any assumptions changed in
accordance with Section III, Acceptable Assumption Changes, in PBGC’s SFA
assumptions guidance (other than the acceptable assumption change for “missing”
terminated vested participants described in Section III.F of PBGC’s SFA assumptions
guidance). This item is also not required if the requested SFA amount from Section C,
Item (4) is the same as the amount shown in the Baseline details of Section C, Item (5).
If the assumptions/methods used to determine the requested SFA amount differ from
those in the “Baseline” projection in Section C, Item (5), then provide a reconciliation of
the change in the total amount of SFA due to each change in assumption/method from the
Baseline to the requested SFA as shown in Section C, Item (4). For each
assumption/method change from the Baseline through the requested SFA amount,
provide a deterministic projection in the same format as Section C, Item (4). Detailed
14

explanations and supporting rationale and information for each assumption/method
change is required in Section D, Item (6)b.
Example – Consider the same Plan A example in Section C, Item (5) above. When
completing this Section C, Item (6), the reconciliation should show the change in SFA
(and corresponding projection information) for each of the assumption changes not
reflected in the Baseline – change in CBU assumptions from the “extended” acceptable
assumption to the CBU assumption used to determine the requested SFA as shown in
Section C, Item (4), change in withdrawal liability payments, change in retirement rates,
and change in assumed payment forms. Below is an example of the reconciliation
information to be shown:
Item number

Basis for
Assumptions/Methods

Change in SFA Amount
(in $million)
(from prior item number)

SFA Amount
(in $million)

1

Baseline

N/A

$6.0

2

CBU

$3.0

$9.0

3

Withdrawal Liability

$(0.2)

$8.8

4

Retirement

$0.7

$9.5

5

Payment form

$0.2

$9.7

(7) Assumption/method changes. Template 7:
a.

This item is not required if the plan is eligible for SFA under § 4262.3(a)(2) or
§ 4262.3(a)(4) of PBGC’s SFA regulation or if the plan is eligible based on a certification
of plan status completed before January 1, 2021. This item is also not required if the plan
is eligible based on a certification of plan status for SFA eligibility purposes completed
after December 31, 2020, but reflects the same assumptions as those in the pre-2021
certification of plan status.
A table identifying which assumptions (and methods) used in determining the plan’s
eligibility for SFA differ from those used in the pre-2021 certification of plan status and
brief explanations as to why using those original assumptions/methods is no longer
reasonable and why the changed assumptions/methods are reasonable. This should be an
abbreviated version of information provided in Section D, Item (6)a.

b.

A table identifying which assumptions (and methods) used in calculating the amount of
SFA differ from those used in the pre-2021 certification of plan status (except the interest
rates used to determine SFA) and brief explanations as to why using those original
assumptions is no longer reasonable and why the changed assumptions are reasonable.
Please state if the changed assumption is an extension of the CBU assumption or the
15

administrative expenses assumption as described in Paragraph A, “Adoption of
assumptions not previously factored into pre-2021 certification of plan status,” of Section
III, Acceptable Assumption Changes, in PBGC’s guidance on Special Financial
Assistance Assumptions. This should be an abbreviated version of information provided
in Section D, Item(6)b.
Example – Consider the same Plan A example in Section C, Item (5) above. When
completing Section C, Item (7)b., the plan should identify all assumption changes (except
the interest rates) -- including those reflected in the Baseline.
Assumption That Has Changed From
Assumption Used in Most Recent
Certification of Plan Status Completed
Before 1/1/2021
Mortality
Administrative Expenses
CBU
Withdrawal Liability
Retirement
Payment Form
(8) Contributions and withdrawal liability details. Template 8: Provide details of the
projected contributions and withdrawal liability payments used to calculate the requested
SFA amount. This should include total contributions, contribution base units (including
identification of base unit used (i.e., hourly, weekly)), average contribution rate(s),
reciprocity contributions (if applicable), additional contributions from the rehabilitation
plan (if applicable), and any other identifiable contribution streams. Provide the projected
number of active participants at the beginning of each plan year. For withdrawal liability,
separately show amounts for currently withdrawn employers and for future assumed
withdrawals.
(9) Participant data. For plans with 350,000 or more participants reported on line 6f of the
most recently filed Form 5500, provide the full individual participant census data (do not
provide any personally identifiable information) utilized by the plan actuary in developing
the cash flow projections included in the application.
(10) Assumption summaries. Template 10: A table identifying and describing all assumptions
and methods used in: i) the pre-2021 certification of plan status, ii) the “Baseline”
16

projection in Section, C Item (5), and iii) the determination of the amount of SFA in
Section C, Item (4).
•

For each assumption or method used in the pre-2021 certification of status, identify
the name of the source document (actuarial valuation report, zone certification,
other plan statement) included with the SFA application and the corresponding page
number of the source document that the assumption can be found.

•

State if a changed assumption falls under Section III, Acceptable Assumption
Changes, or Section IV, Generally Accepted Assumption Changes, in PBGC’s SFA
assumptions guidance, or if it should be considered an “Other Change.”

•

Provide the cash flow timing used in items (i), (ii), and (iii) above.

•

Complete all rows of Template 10. If an assumption on Template 10 does not apply
to the application, enter “N/A” and explain as necessary in the “comments” column.
If the application contains assumptions not listed on Template 10, create additional
rows as needed.

If the plan uses a SFA measurement date after February 15, 2023, the signing actuary
is required to provide a statement indicating that in their professional opinion, the
combined effect of non-prescribed assumptions used for measuring the pension
obligations used to determine SFA does not have significant bias.
Example – Consider the same Plan A example in Section C, Item (5) above. When completing
Section C, Item (10), the plan should identify all method/assumption changes and complete
all rows of Template 10, not just the example items below.
(A)

Base
Mortality –
Healthy

Contribution
Base Units

Source of
(B)
2019 Plan
A AVR.pdf
p. 55

2020 Plan
A ZC.pdf p.
19

(B)
Assumption/Method
Used in Most Recent
Certification of Plan
Status Completed Prior
to 1/1/2021

(C)

Baseline
Assumption/
Method Used
Pri-2012(BC)
mortality
RP-2000 mortality table
table
125,000
hours
projected
through the
SFA
projection
125,000 hours projected
period in
to insolvency in 2028
2051
17

(D)
Final SFA
Assumption/
Method Used

(E)
Category of
assumption change
from (B) to (D) per
SFA Assumption
Guidance

Same as baseline

Acceptable Change

100,000 hours
projected with 3.0%
reductions annually
for 10 years and
1.0% reductions
annually thereafter

Generally
Acceptable Change

SECTION D – Plan statements. The filer uploads a single document (with a unique page
number on each page of the document) as document type “Special Financial Assistance
Application” to the e-Filing Portal with responses to the following information requirements.
This document must be signed and dated by an authorized trustee who is a current member of the
board of trustees or an authorized representative of the plan sponsor and include the printed name
and title of the signer.
(1) Provide an SFA request cover letter for the application (optional, except as follows):
a. For a MPRA plan, include an SFA request cover letter that identifies the calculation
method (basic method, increasing assets method, or present value method) that
provides the greatest amount of SFA. See Section C, Item (4).
b. For a MPRA plan with a partition, include an SFA request cover letter that includes
a statement that the plan has been partitioned under section 4233 of ERISA.
(2) Provide the name, address, email, and telephone number of the plan sponsor and the plan
sponsor’s authorized representative, and any other authorized representatives.
(3) Identify which of the following eligibility criteria qualify the plan to be eligible for SFA.
Provide additional information as required below for each item that is applicable. If the
plan is eligible for SFA under multiple criteria, the filer may (but is not required to)
identify and provide the required additional information for more than one.
a. In any plan year beginning in 2020, 2021, or 2022, the plan is certified by the plan
actuary to be in critical and declining status. Identify which plan year(s) apply and
refer to information required in Section B, Item (5) and if applicable, Section E,
Item (2).
b. The plan has been approved for a suspension of benefits under section 305(e)(9) of
ERISA as of March 11, 2021.
c. The plan satisfies the eligibility requirements for a critical status plan under
§ 4262.3(a)(3) of PBGC’s SFA regulation. The conditions do not need to be
satisfied for the same plan year.
i. In any plan year beginning in 2020, 2021, or 2022, the plan is certified by
the plan actuary to be in critical status within the meaning of section
305(b)(2) of ERISA. Identify the specified year(s) and refer to information
required in Section B, Item (5) and if applicable, Section E, Item (3).
Election of critical status under section 305(b)(4) of ERISA does not satisfy
the requirement for the certification of critical status by the plan’s actuary.
ii. The percentage calculated under § 4262.3(c)(2) of PBGC’s SFA regulation
for 2020, 2021, or 2022 is less than 40 percent. Identify which year’s Form
5500 Schedule MB is used by the plan for eligibility; the current value of net
18

assets entered by the plan on line 2a of the Form 5500 Schedule MB; the
current value of withdrawal liability due to be received by the plan on an
accrual basis, reflecting a reasonable allowance for amounts considered
uncollectible (if not already included in the current value of net assets); and
the current liability measurement entered by the plan on line 2b(4) column
(2) of the Form 5500 Schedule MB.
iii. On the Form 5500 that was required to be filed for plan year 2020, 2021, or
2022, the ratio of active participants that is entered on line 6a(2) to inactive
participants (that is the sum of lines 6b, 6c, and 6e) is less than 2 to 3.
Identify which year’s Form 5500 is used by the plan for eligibility and the
number of active participants entered by the plan on line 6a(2) and the
number of inactive participants that is the sum of lines 6b, 6c, and 6e.
Alternatively based on the Schedule MB of the Form 5500 that was required
to be filed for plan year 2020, 2021 or 2022, the ratio of the total number of
active participants at the beginning of the plan year that is entered as the
number of participants on line 2b(3)(c) to inactive participants (that is the
sum of retired participants and beneficiaries receiving payment on line 2b(1)
and terminated vested participants on line 2b(2)) is less than 2 to 3. Identify
which year’s Schedule MB of the Form 5500 is used by the plan for
eligibility and the number of active participants entered by the plan on line
2(b)(3)(c) and the number of inactive participants that is the sum of lines
2b(1) and 2(b)(2).
d. The plan became insolvent after December 16, 2014, and remained insolvent
without terminating as of March 11, 2021.
(4) If the plan’s application is submitted on or before March 11, 2023, identify which priority
group the plan is in (see § 4262.10(d)(2) of PBGC’s SFA regulation). If the plan is
submitting an emergency application under § 4262.10(f), identify the application as an
emergency application and which emergency criteria is applicable.
(5) Provide a detailed narrative description of the development of the assumed future
contributions (including assumed contribution rates) and the assumed future withdrawal
liability payments used to calculate the SFA amount as shown in Section C, Item (4).
(6) Provide the following:
a. If the plan is eligible for SFA under § 4262.3(a)(1) or § 4262.3(a)(3) of PBGC’s SFA
regulation, and the assumptions used to determine such eligibility are different from
the assumptions used in the most recent actuarial certification of plan status completed
before January 1, 2021, identify which assumptions are different, and provide detailed
explanations and supporting rationale and information as to why using the identified
assumptions is no longer reasonable and why the changed assumptions are reasonable.

19

b. If any assumptions or methods used to determine the SFA amount are different from
those used in the most recent actuarial certification of plan status before January 1,
2021 (excluding the plan’s non-SFA and SFA interest rates, which must be the same
as the interest rates required under § 4262.4(e)(1) and (2)), identify which
assumptions/methods are different, and provide detailed explanations and supporting
rationale and information as to why using the identified original assumptions is no
longer reasonable and why the changed assumptions are reasonable. Please state if the
changed assumption is an extension of the CBU assumption or the administrative
expenses assumption as described in Paragraph A, “Adoption of assumptions not
previously factored into pre-2021 certification of plan status,” of Section III,
Acceptable Assumption Changes, in PBGC’s SFA assumptions guidance.
The information to be provided in Items (6)a. and (6)b. is intended to be a more
detailed explanation with supporting rationale and information than the brief summary
that is provided in Section C, Items (7)a. and (7)b.
Following are examples of supporting rationale and information for different types of
assumption changes:
•

For changes to demographic assumptions such as retirement and turnover –
experience study including detailed summary of actual experience and
documentation of data sources and methodologies used.

•

For changes to optional payment form assumptions – historical distribution
of payment form selected at retirement.

•

For changes to the new entrant profile – historical distribution (by year) of
ages of all new entrants (whether new hires or rehires) and other relevant
demographic characteristics such as service or pay.

•

For changes to contribution assumptions including CBUs and contribution
rates – narrative explanation of historical trends, rationale for assumption
and explanation of consistency between CBU assumptions, contribution
rates and assumed rates of future employer withdrawals.

•

For changes in assumed collectability of withdrawal liability – historical
data on collectability and, if applicable, how other relevant factors were
considered.

•

For changes in assumed rate of future employer withdrawals – relevant
historical data and, where appropriate, relevant industry or geographic
information.

•

For changes to the initial amount of administrative expenses, – detailed
supporting rationale for the amount of change in each type of administrative
expense (e.g., legal, plan administration, office expenses, etc.)
20

•

For changes to the assumption used to increase administrative expenses –
forward-looking expectations from credible sources.

•

For changes to the assumption for which terminated vested participants are
included or excluded from the determination of SFA, see PBGC’s SFA
assumptions guidance (Sections III.F and VI.C).

Supporting information to be provided if a plan-specific mortality table or a plan
specific adjustment to a standard mortality table is used (regardless of if the
mortality assumption is changed or unchanged from the pre-2021 certification of
plan status) should comprehensively document the methodology used and rationale
for selection of the methodology used (including, but not limited to, the selection
of the base table and improvement scale, methodology for weighting of mortality
experience, method for adjusting the base table, experience period used, and
handling of different participant groups (e.g., gender, pay status)) to develop the
plan-specific rates, as well as detailed information showing the determination of
plan credibility and plan experience.
For any changed assumption for which future expectations differ significantly from
historical experience, provide rationale for the difference and supporting
information.
(7) This item is required only if the plan suspended benefits under section 305(e)(9) or section
4245(a) of ERISA.
Provide a narrative description of how the plan will reinstate the benefits that were
previously suspended and a proposed schedule of payments (equal to the amount of
benefits previously suspended) to participants and beneficiaries under the plan. The
proposed schedule should show the yearly aggregate amount and timing of such payments
and assume for purposes of determining SFA only that the effective date for reinstatement
is no later than the day after the SFA measurement date, as shown under Section C, Item
(4)e. If the plan restored benefits under 26 CFR 1.432(e)(9)-1(e)(3) before the SFA
measurement date, the proposed schedule should reflect the amount and timing of
payments of restored benefits and the effect of the restoration on the benefits remaining to
be reinstated. For more information regarding the reinstatement of benefits, see guidance
issued by the Treasury Department and IRS (Notice 2021-38).
SECTION E – Checklist, certifications, and SFA-related plan amendments. The filer
completes and uploads the Application for Approval of Special Financial Assistance Checklist to
the e-Filing Portal, to ensure that the filer has uploaded the required information using, where
applicable, the required filenames identified on the SFA Application Checklist.

21

All certifications from the plan’s enrolled actuary should include, where applicable, clear indication
of all 2 assumptions and methods used, including source of and date of participant census data, the
count of participants (provided separately, after reflection of the death audit results in Section B(9),
for current retirees and beneficiaries, current terminated vested participants not yet in pay status, and
current active participants) as of the participant census date, the SFA measurement date and a
statement that the actuary is qualified to render the actuarial opinion. All certifications from the
enrolled actuary must be signed and dated.
The filer uploads the following documents to the e-Filing Portal.
(1) SFA Application Checklist.
(2) SFA Eligibility Certification and Supporting Information for Critical and Declining Plan.
If the plan claims SFA eligibility under § 4262.3(a)(1) of PBGC’s SFA regulation based on
the certification from the plan’s enrolled actuary of plan status completed before January 1,
2021, no information is required for this Item (2), but the applicable zone certification and
supplemental information should be provided in Section B, Item (5).
If the plan claims SFA eligibility under § 4262.3(a)(1) of PBGC’s SFA regulation based on
a certification by the plan’s enrolled actuary of plan status for SFA eligibility purposes
completed on January 1, 2021, or later, the following items should be included as a single
document for this Item (2).
a. Plan actuary’s certification of plan status for SFA eligibility purposes for the
specified year (and, if applicable, for each plan year after the plan year for which
the pre-2021 zone certification was prepared and for the plan year immediately prior
to the specified year). For example, if the specified year used for SFA eligibility
purposes is the 2022 plan year, and the pre-2021 zone certification is for the 2020
plan year, then provide the plan actuary’s certification of plan status for SFA
eligibility purposes for the 2021 and 2022 plan years.
b. For each certification in a. above, include all details and additional information as
described in Section B, Item (5), including clear documentation of all assumptions,
methods, and census data used.

Identify all demographic assumptions used (e.g., healthy mortality, disabled mortality, mortality improvement,
retirement for actives, retirement for terminated vested participants, turnover, disability, assumed payment form
for actives, assumed payment form for terminated vested participants, marital status, spouse age difference, and
new entrant profile). Also identify the assumption used for projecting active participant counts. Identify how
missing or incomplete data is handled or state that there is no missing or incomplete data. Identify whether any
plan participants are excluded from the projections, or state that there are no exclusions. Clearly state the
participant census date. Identify projection assumptions including CBUs, contribution rates and whether
contribution rates are the current rates in CBAs in effect as of July 9, 2021, whether there were substantial
contribution rate decreases negotiated after March 11, 2021, administrative expenses, and withdrawal liability
payments (separately for currently withdrawn employers and future assumed withdrawals). Identify any
assumptions related to reciprocity, or state there are no such assumptions and why.
2

22

c. For each certification in a. above, identify all assumptions and methods that are
different from those used in the pre-2021 zone certification.
(3) SFA Eligibility Certification and Supporting Information for Critical Plan. If the plan claims
SFA eligibility under § 4262.3(a)(3) of PBGC’s SFA regulation, the following items should
be included as a single document for this Item (3).
a. If the plan claims SFA eligibility under § 4262.3(a)(3) of PBGC’s SFA regulation
based on a certification by the plan’s enrolled actuary of plan status completed
before January 1, 2021, the zone certification and additional information provided
in Section B, Item (5) is sufficient and does not need to be separately provided
here.
If the plan claims SFA eligibility under § 4262.3(a)(3) of PBGC’s SFA regulation
based on a certification by the plan’s enrolled actuary of plan status for SFA
eligibility purposes completed on January 1, 2021, or later, include here the same
information identified in Item (2)a., b., and c. above.
b. A certification from the plan’s enrolled actuary that the plan qualifies for SFA
based on the applicable certification of plan status for SFA eligibility purposes for
the specified year, and by meeting the other requirements of § 4262.3(c) of
PBGC’s SFA regulation. The certification should specifically note the specified
year for each component of eligibility (certification of plan status for SFA
eligibility purposes, modified funding percentage, and participant ratio), the
derivation of the modified funded percentage, and the derivation of the participant
ratio. The certification should identify what test(s) under section 305(b)(2) of
ERISA is met for the specified year listed above. The certification must identify
all assumptions and methods (including supporting rationale, and where applicable,
reliance on the plan sponsor) used to develop the current value of the withdrawal
liability that is utilized in the calculation of the modified funded percentage.
(4) Priority Status. This actuarial certification is not required if the plan is insolvent under
section 4245(a) of ERISA, or has implemented a suspension of benefits under section
305(e)(9) of ERISA as of March 11, 2021, or is in critical and declining status (as defined in
section 305(b)(5) of ERISA) and had 350,000 or more participants, or is listed on PBGC’s
website at www.pbgc.gov as a plan in priority group 6 as defined under § 4262.10(d)(2)(vi).
If the plan is filing an application on or before March 11, 2023, a certification from the
plan’s enrolled actuary that the plan is eligible for priority status, with specific
identification of the applicable priority group. This certification should include sufficient
information to demonstrate that the plan is eligible for the identified priority group,
including details of relevant plan projections and clear documentation of all assumptions,
methods, and census data used in such projections.
(5) SFA Amount Certification. A certification from the plan’s enrolled actuary that the
requested amount of SFA is the amount to which the plan is entitled. The following items
should be included as a single document for this Item (5).
23

a. Plan actuary’s certification that identifies the requested amount of SFA and
certifies that this is the amount to which the plan is entitled under section
4262(j)(1) of ERISA and § 4262.4 of PBGC’s SFA regulation.
b. For a MPRA plan, identification of the amount of SFA determined under the “basic
method” described in § 4262.4(a)(1) of PBGC’s SFA regulation and the
“increasing assets method” under § 4262.4(a)(2)(i).
c. For a MPRA plan, if the amount of SFA determined under the “present value
method” described in § 4262.4(a)(2)(ii) is not the greatest amount of SFA under
§ 4262.4(a)(2), a statement certifying as such.
d. For a MPRA plan, if the amount of SFA determined under the “present value
method” described in § 4262.4(a)(2)(ii) is the greatest amount of SFA under
§ 4262.4(a)(2), identification of the amount of SFA determined under the “present
value method.”
e. Identify all assumptions and methods used, including the SFA measurement date
and other relevant information. Provide a summary of and identify the sources of
participant census data used, the participant census date, the count of participants
(provided separately, after reflection of the death audit results in Section B(9), for
current retirees and beneficiaries, current terminated vested participants not yet in
pay status, and current active participants) as of the participant census date.
(6) Fair Market Value Certification. A certification from the plan sponsor with respect to the
accuracy of the amount of the fair market value of assets as of the SFA measurement date,
including relevant supporting information. For MPRA plans, this certification is required
even if the requested SFA amount is based on the “present value method” under §
4262.4(a)(2)(ii) of PBGC’s SFA regulation. The following items should be included as a
single document for this Item (6).
a. Plan sponsor’s certification that explicitly identifies and certifies the amount of the
fair market value of assets as of the SFA measurement date that is used in the
calculation of the SFA amount using the “basic method” and, if applicable, the
“increasing assets method”.
b. Information that substantiates the asset value and how it was developed (e.g., trust
or account statements, specific details of any adjustments).
c. If the SFA measurement date is later than the end of the plan year for the most
recent audited plan financial statements, provide a reconciliation of the fair market
value of assets from the date of the most recent audited plan financial statements to
the SFA measurement date. The reconciliation should show the beginning and
ending fair market value of assets for this period, as well as the following items for
the period: contributions, withdrawal liability payments, benefits paid,
administrative expenses, and investment income. The reconciliation should also
24

identify changes (with explanations), if any, to payables or receivables reflected in
the audited plan financial statements.
d. If the SFA measurement date is the end of a plan year for which the audited plan
financial statements have been issued, provide a reconciliation schedule showing
adjustments, if any, made to the audited fair market value of assets used to
determine the SFA amount.
e. To the extent that the fair market value of assets includes accruals that overlap with
the Template 4A solvency projection – that is, accrual items related to
contributions, withdrawal liability payments, other payments, benefit payments,
make-up payments, or administrative expenses – and those accrual items are
expected to be received or paid over the SFA projection period, the SFA
calculation will need to be adjusted, if applicable, in order to avoid double counting
(e.g., adjust the Template 4A cash flows in the initial projection year).
(7) Executed Plan Amendment for SFA Compliance. A copy of the executed plan amendment
required by § 4262.6(e)(1) of PBGC’s SFA regulation. The plan amendment must comply with
the following requirements.
a. The plan amendment must be executed by either:
(i) All trustees serving on the plan’s board of trustees at the time the amendment was
adopted; or
(ii) If executed by fewer than all trustees, those trustees to whom the plan’s board of
trustees has delegated the specific authority to amend the plan document in
accordance with § 4262.6(e)(1) provided the plan’s governing documents permit that
delegation.
Note: A resolution authorizing a subset of trustees to act on behalf of the board that does
not delegate to those trustees the specific authority to amend the plan document in
accordance with § 4262.6(e)(1) will be considered insufficient. For example, a resolution
delegating the authority to “sign any document required for the SFA application” will be
considered insufficient.
b. The plan amendment must include the following provision, which must be effective
through the end of the last plan year ending in 2051:
Beginning with the SFA measurement date selected by the plan in the plan's
application for special financial assistance, notwithstanding anything to the contrary
in this or any other governing document, the plan shall be administered in accordance
with the restrictions and conditions specified in section 4262 of ERISA and 29 CFR
part 4262. This amendment is contingent upon approval by PBGC of the plan's
application for special financial assistance.
A model plan amendment that includes the required information is available here.
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(8) Proposed Plan Amendment to Reinstate Benefits. In the case of a plan that suspended
benefits under section 305(e)(9) or section 4245(a) of ERISA, the following items should be
included as a single document for this Item (8).
a. The proposed plan amendment(s) to reinstate suspended benefits and pay makeup
payments, required by § 4262.6(e)(2) of PBGC’s SFA regulation. A model
proposed plan amendment that includes the required information is available here.
b. A certification by the plan sponsor that the proposed plan amendment(s) to
reinstate suspended benefits and pay make-up payments will be timely adopted.
A model certification that includes the required information is available here.
c. The certification in b. must be signed either by all members of the plan’s board of
trustees or by one or more trustees duly authorized to sign the certification on
behalf of the entire board and to commit the board to timely adopting the
amendment after the plan’s application for SFA is approved, with each signature
accompanied by the printed name and title of the signer.
d. If such certification is not signed by all members of the board of trustees,
documentation that substantiates the authority of one or more trustees duly
authorized to sign on behalf of the entire board.
(9) Executed Plan Amendment to Rescind Partition Order. In the case of a plan that was
partitioned under section 4233 of ERISA that is eligible for SFA under § 4262.3(a)(2) of
PBGC’s SFA regulation, a copy of the executed plan amendment which (i) is signed by an
authorized trustee of the plan and (ii) removes any provisions or amendments that were
required to be adopted under the partition order, as required by § 4262.9(c)(2) of PBGC’s
SFA regulation, which also includes the following: “This amendment is contingent upon
approval by PBGC of the plan's application for special financial assistance.”
(10) One or more copies of the following statement that: (a) is signed by an authorized trustee
who is a current member of the board of trustees, (b) includes the trustee’s printed name and
title, and (c) reads:
“Under penalty of perjury under the laws of the United States of America, I declare that I
am an authorized trustee who is a current member of the board of trustees of the [insert
plan name] and that I have examined this application, including accompanying documents,
and, to the best of my knowledge and belief, the application contains all the relevant facts
relating to the application, all statements of fact contained in the application are true,
correct, and not misleading because of omission of any material fact; and all accompanying
documents are what they purport to be.”
What happens after an application is filed
After an application is filed, the filer will hear from PBGC within 120 days of the filing date. The
application will be either approved or denied. If the application is approved, the plan will receive
further instructions from PBGC on how the SFA amount will be transferred. If the application is
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denied, the filer will receive written notice from PBGC providing the reasons for the denial.
PBGC may deny an application because it is incomplete; because an assumption is unreasonable,
a proposed change in assumption is unreasonable individually, or the proposed changed
assumptions are unreasonable in the aggregate; or because the plan is not an eligible
multiemployer plan. The filer then may submit a revised application no later than December 31,
2026.
An authorized filer may withdraw an application at any time before PBGC denies or approves the
application. To withdraw an application, the filer must send an email to the Multiemployer
Program Division mailbox at multiemployerprogram@pbgc.gov and include as the subject
“Withdrawal of Special Financial Assistance Application of (Plan Name).” The body of the email
should read, “On behalf of (Plan Name), I withdraw the special financial assistance application
filed on (filing date)” and include the filer’s title, relation to the plan, and other information to
demonstrate that the filer is an individual authorized to withdraw the SFA application. If a filer
decides to submit an application following withdrawal, then the newly filed application will be
considered a revised application. For the revised application, the filer needs to submit only the
information that is changed from the initial application. The filer may state on the SFA
Application Checklist that other information was previously filed.
A revised application for SFA must use the same SFA measurement date, participant census data,
non-SFA interest rate, and SFA interest rate as were used in the plan’s initial application (this is
the plan’s “base data,” see § 4262.11(c)). Also, if a plan received a transfer of benefit liabilities
from another plan that previously filed an initial application for SFA, then PBGC will treat the
transferee plan’s application as a revised application and require the revised application to use the
base data of the transferor plan’s initial application.
Under certain circumstances, a filer may request an “amendment,” meaning that the plan is
withdrawing its most recently filed application for SFA and seeking expedited review of a revised
application. This procedure to request an amendment is available to a plan if the revised
application is only changing as a result of: inaccurate information, arithmetic errors, input errors,
formula errors, and small to moderate assumption changes reflecting feedback from PBGC staff
on the assumptions used in the application.
A plan may submit an amendment if it meets the following requirements.
•
•
•

The plan has not yet withdrawn its most recently filed application;
Less than 100 days have elapsed since the plan filed its previous application; and
The revised application is submitted when the previous application is withdrawn.

See SFA Application Amendment Cover Letter for more information.
An interim final rule filer (“IFR filer”) described under § 4262.4(g) of PBGC’s SFA regulation
that files a revised application must use the following base data, see § 4262.4(g)(5):
(1) The plan’s SFA measurement date determined as the last day of the calendar quarter
immediately preceding the date the plan’s initial application for SFA was filed;
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(2) The plan’s participant census data required to be used in the plan’s initial application for
SFA under the interim final rule; and
(3) The plan’s non-SFA interest rate and SFA interest rate determined under § 4262.4(e)(1)
and (2).
The IFR filer submitting a revised application must otherwise submit all information required
under these general instructions (and Addendums A and D, as applicable). If a required document
has already been submitted with the initial or an earlier revised application, the IFR filer does not
need to re-submit that document, but the filer should identify in the SFA Application Checklist
that it was previously submitted and its submission date.
An IFR filer that has already received payment of SFA under the terms of the interim final rule
and wishes to submit a supplemented application must follow the instructions in Addendum C.
Finally, during the 120-day review period, PBGC may require a plan sponsor to file additional
information, including information to clarify or verify information provided in the plan’s
application. The plan sponsor must promptly file with PBGC any such information upon request.
If PBGC does not receive the requested information, the application may be considered
incomplete, and if an error or omission in an application requires a change to the amount of SFA
requested, the application will be considered incomplete.

Paperwork Reduction Act Notice
This section provides information on the time and cost estimates for preparing and filing the
required application. If you have any comments concerning the accuracy of these estimates or
suggestions for making it simpler to submit the information, please send your comments to the
Pension Benefit Guaranty Corporation, Office of the General Counsel, 445 12th Street, SW,
Washington, DC 20024-2101.
Information filed with PBGC in an application for special financial assistance (SFA) is
confidential only to the extent provided in the Privacy Act. PBGC may, in its sole discretion, post
an application for SFA and any documents and information filed for the application on its website
at www.pbgc.gov, or otherwise publicly disclose the application, documents, and information,
except information that is confidential under the Privacy Act.
PBGC will share with the U.S. Department of Labor and the Treasury Department (collectively the
Agencies) a plan’s application, including any documents and information filed with PBGC, to
enable the Agencies to fulfill their responsibilities under ERISA.
This information collection is necessary for PBGC to properly administer the SFA program.
PBGC uses the information it receives in a plan’s application to determine, as required by section
4262 of ERISA and 29 CFR part 4262, whether to approve or deny the requested payment of SFA
to the plan.

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PBGC estimates an average burden of 12 hours of Fund office time and $34,000 in contractor
costs per plan. These are estimates and the actual time and cost per plan will vary depending on
the circumstances of a given filing and the size of the plan.
This collection of information has been approved by the Office of Management and Budget
(OMB) under control number 1212-0074 (expires 05/31/2024). Under the Paperwork
Reduction Act, an agency may not conduct or sponsor, and a person is not required to respond
to, a collection of information unless it displays a currently valid OMB control number.

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