Pension risk transfer and plan termination support

A standard termination runs through seven steps, from choosing the proposed termination date to the post-distribution certification. The diagram shows the order, with the enrolled actuary's certification as the signer step. The plan administrator picks a proposed termination date and issues the notice of intent to terminate to affected parties. The enrolled actuary completes Schedule EA-S, which goes in the Standard Termination Notice, Form 500, filed with the PBGC. PBGC then has 60 days to review a complete filing. After that the plan distributes benefits as lump sums or annuities, and files Form 501 once distribution is complete.

An affected party is a participant, a beneficiary of a deceased participant, an alternate payee under a qualified domestic relations order or an employee organization representing participants. The PBGC itself does not receive the notice of intent to terminate.

Six deadlines govern a standard termination, and PBGC's filing instructions give each one; the table lists them. The distribution deadline needs the most care, because it depends on when PBGC's review period ends and on whether an IRS determination letter was requested.

Source: PBGC Standard Termination Filing Instructions, opened 2026-10-02. For a plan with missing participants whose termination date is on or after January 1, 2018, the filing uses Form MP-100.

A lump-sum window offers participants a limited-time choice to take the present value of their benefit as one payment. The present value depends on the interest rates and mortality table in force on the date the benefit is valued, so the same benefit can be worth less when rates are higher. For distributions under section 417(e)(3), the IRS publishes monthly spot segment rates; for August 2026 they were 4.65, 5.75 and 6.73 for the first, second and third segments (Notice 2026-57). The unisex mortality table for stability periods beginning in 2026 is in Notice 2025-40.

Finbryn builds the calculation file: each participant's benefit, the lump-sum value under the plan's rate rule and an estimate of how many accept at several take-up levels, so the sponsor can see the cash needed. It does not decide the offer. The plan's fiduciaries and counsel do that, and an enrolled actuary named in the engagement letter signs any certification that is required.

Covered single-employer plans pay the PBGC a flat per-participant premium and a variable premium based on underfunding. The 2026 and 2027 rates are in the table, and a terminating plan keeps filing through the plan year in which distribution is completed, though PBGC's 2026 instructions exempt it from the variable-rate premium in the year of final distribution or after a prior-year proposed termination date. The normal due date for a calendar-year plan's 2026 premium is October 15, 2026.

Source: PBGC premium rates page (last updated October 14, 2026, opened 2026-10-16). An enrolled actuary must certify the variable-rate premium calculation unless the plan is exempt, per PBGC's 2026 instructions. Finbryn prepares the premium workpapers for that actuary.

Cost depends on how many participants the plan has, how complete the benefit data is, how many participants cannot be found, whether the plan is fully funded, whether annuities or lump sums are used and how many scenarios the sponsor wants priced. A plan with a clean census and a lump-sum-only design needs far less work than one with partial records and an annuity purchase.

PBGC's own filing instructions estimate an average of 25 hours and $5,100 to comply with standard termination requirements, including missing participant rules. That is the agency's estimate of the burden of its forms, not a provider fee, and the instructions say actual time varies. We did not find a public fee schedule for private-plan termination work, so no provider range is published. Ask each provider to price data cleanup, cost estimates and filing schedules separately. See pricing.

The enrolled actuary signs the certification, and the plan administrator files. PBGC's Schedule EA-S requires the enrolled actuary to complete Parts III and IV, except for certain plans where the plan administrator may sign. The 2026 premium instructions require an enrolled actuary to certify the variable-rate premium in item 21.

Finbryn prepares the data cleanup, cost estimates, shortfall estimate, election-period calculations and filing support schedules. It does not certify sufficiency, file with the PBGC or represent anyone before the PBGC. Schedule EA-S and the variable-rate premium certification stay with an enrolled actuary, and the engagement letter confirms who signs them. Your plan's counsel advises on fiduciary and legal questions. The auditor, if the plan has one, tests the actuary's work.