Employee Plans Compliance Unit (EPCU) - Current Project - Multiemployer Defined Benefit Actuarial Zone Certification - Frequently Asked Questions
These frequently asked questions and answers are provided for general information only and should not be cited as any type of legal authority. They are designed to provide the user with information responsive to general inquiries. Due to the uniqueness and complexities of Federal tax law, it is imperative to ensure a full understanding of the specific question presented, and to perform the requisite research to ensure a correct response is provided. More information on Federal taxation can be obtained directly on our website, www.irs.gov.
- Why is there a need for this project?
- Why have I been selected for a compliance contact?
- What will be the focus of the information request?
Why is there a need for this project?
The Pension Protection Act of 2006 (PPA) required multiemployer defined benefit plans to submit an annual actuarial certification from the actuary no later than 90 days after the beginning of the plan year. Failure to submit timely could result in penalties of $1100. per day and may cause the filing of the form 5500 to be considered to be incomplete or delinquent. The Employee Plans Compliance Unit (EPCU) has been charged with verifying compliance with these provisions of PPA.
A compliance check is not an audit or investigation under §7605(b) of the IRC or an audit under §530 of the Revenue Act of 1978.
Why have I been selected for a compliance contact?
You were selected for a compliance check because we were unable to verify that your plan submitted a zone certification for all relevant years.
What will be the focus of the information request?
You will be asked for information to determine that you properly submitted the required actuarial zone certification for your defined benefit plan as noted on our letter 1562-M. It is possible that you may have previously submitted the certification but used a different plan name, plan number, or Employer Identification number (EIN), or failed to include enough identifying information. It is also possible that the plan is not required to submit an actuarial zone certification because it is not a defined benefit plan, not a multiemployer plan, or has terminated and no longer has an IRC §412 funding requirement. Our objective is to insure that all certifications have been verified as received for all required plans.