# Pension risk transfer and plan termination support

Canonical: https://finbryn.com/us/services/actuarial-services/pension-risk-transfer-plan-termination

Finbryn supports lump-sum windows, annuity purchases and PBGC standard terminations of single-employer pension plans, preparing benefit data, cost estimates and filing schedules. The plan's enrolled actuary signs the Schedule EA-S sufficiency certification, and Form 500 is due by the earlier of 180 days after the proposed termination date or 60 days before distribution.

Pension risk transfer means moving pension obligations off the employer's books. The two common routes are a lump-sum window, where participants are offered a one-time cash-out, and an annuity purchase, where an insurer takes over the payments. When a sponsor ends the plan entirely, a single-employer plan with enough assets to pay every benefit can use the PBGC's standard termination. All three routes need the same groundwork: clean benefit data, cost estimates under current rates and a clear answer on whether the plan is fully funded.

Finbryn prepares that groundwork. It cleans the participant data and builds the missing-participant search list, estimates lump-sum and annuity costs under the rates in force, estimates the funding shortfall before termination, builds the benefit and election-period calculations and lays out the schedules that support the PBGC filing. It does not choose the insurer, advise the plan fiduciaries or certify sufficiency.

The filing signatures follow PBGC's rules. A standard termination notice, PBGC Form 500, includes Schedule EA-S, the certification that the plan can pay all benefits. Part IV of that schedule is completed by an enrolled actuary, with a narrow exception for certain plans where the plan administrator may sign. The plan administrator files the notice. Finbryn sends its schedules to the enrolled actuary, and the engagement letter confirms who signs the filing.

Timing is set by statute and PBGC rules, and a missed step can nullify the termination. The notice of intent to terminate goes out 60 to 90 days before the proposed termination date. Form 500 is due within 180 days after that date. Distribution must finish by a deadline tied to PBGC's 60-day review. If your firm sends plans to a TPA or actuary, see [white-label actuarial support](/services/actuarial-services/white-label-actuarial-support). For ongoing valuations before a plan ends, see [cash balance and defined benefit plan support](/services/actuarial-services/cash-balance-defined-benefit-plans).

What you get: Benefit data cleanup and missing-participant search list; Lump-sum and annuity cost estimates under current rates; Funding shortfall estimate before termination; PBGC standard termination filing support schedules; Participant election-period calculations; A deadline calendar from notice of intent through Form 501

Software we work in: Microsoft Excel, Python

How filing works: We prepare the return and the working papers. A credentialed signer or licensed partner signs and files it, or you file it yourself.

## How does a PBGC standard termination run?

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.

Diagram: A PBGC standard termination, step by step. Seven steps: choose the proposed termination date, notice of intent to terminate, enrolled actuary signs Schedule EA-S, file Form 500, PBGC 60-day review, distribute benefits, file Form 501.

## What are the standard termination deadlines?

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.

| Step | Deadline | Who acts |
| --- | --- | --- |
| Notice of intent to terminate | At least 60 and not more than 90 days before the proposed termination date | Plan administrator |
| Notice of plan benefits | No later than the Form 500 filing | Plan administrator |
| Form 500 with Schedule EA-S | The earlier of 180 days after the proposed termination date, or 60 days before any distribution | Plan administrator, enrolled actuary signs EA-S |
| Notice of annuity information | At least 45 days before the distribution date, if an annuity may be used | Plan administrator |
| Distribute plan assets | Later of 180 days after PBGC's 60-day review ends, or 120 days after a favorable IRS determination letter if requested by the Form 500 filing | Plan administrator |
| Form 501 post-distribution certification | Within 30 days after all benefits are distributed (60 days with an email to PBGC inside the 30) | Plan administrator |

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.

## How does a lump-sum window work?

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.

## What do PBGC premiums cost before the plan ends?

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.

| Plan years beginning in | Flat rate, per participant | Variable rate, per $1,000 unfunded vested benefits | Variable-rate cap, per participant |
| --- | --- | --- | --- |
| 2027 | $116 | $52 | $783 |
| 2026 | $111 | $52 | $751 |
| 2025 | $106 | $52 | $717 |

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.

## What does termination or risk transfer support cost?

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](/pricing).

## Who signs, and what does Finbryn prepare?

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.

## The process

1. **Scope the plan and gather the records**: Plan document, amendments, participant census, benefit statements, asset report and any prior valuations.

2. **Clean the benefit data**: Reconcile records, flag gaps and build the missing-participant search list.

3. **Estimate costs and the funding position**: Lump-sum and annuity cost estimates under current rates, and an estimate of any shortfall before termination.

4. **Prepare notice and election-period calculations**: Benefit figures for the notices of plan benefits and the election period, for the plan administrator to issue.

5. **Prepare the Form 500 support schedules**: Data and calculation exhibits laid out for the enrolled actuary's Schedule EA-S.

6. **The enrolled actuary reviews and signs**: The actuary completes and signs Schedule EA-S, and the plan administrator files Form 500 with PBGC.

7. **PBGC and the auditor review the filing**: PBGC reviews a complete filing for 60 days. The auditor tests the work. Follow-up data questions run through the plan administrator.

## Common problems we fix

| The problem | How we fix it |
| --- | --- |
| Participant records are incomplete or missing | Data cleanup produces a record-by-record exceptions list and a search list before notices go out, so gaps are known early. |
| The plan may not have enough assets to terminate | A shortfall estimate under current rates shows the gap and the sponsor's options before the proposed termination date is chosen. |
| A distribution date is missed after PBGC review | The deadline calendar ties the distribution deadline to the end of PBGC's 60-day review and any IRS determination letter request. |
| Lump-sum offers change with interest rates | Cost estimates are rerun at the latest published segment rates, so the cash needed is current when the window opens. |
| Annuity notices are late | The calendar flags the 45-day annuity information notice and the 30-day annuity contract notice for the plan administrator. |

## By the numbers

| Figure | What it means | Source |
| --- | --- | --- |
| $111 per participant | PBGC 2026 flat-rate premium for single-employer plans, plus $52 per $1,000 of unfunded vested benefits, capped at $751 per participant | [pbgc.gov/employers-practitioners/premium-filings/rates](https://www.pbgc.gov/employers-practitioners/premium-filings/rates) (2026-10-16) |
| 60 to 90 days | window for the notice of intent to terminate, before the proposed termination date | [pbgc.gov/sites/default/files/documents/instructions-500-series.pdf](https://www.pbgc.gov/sites/default/files/documents/instructions-500-series.pdf) (2026-10-02) |
| 180 days | latest Form 500 filing after the proposed termination date, or 60 days before any distribution if earlier | [pbgc.gov/sites/default/files/documents/instructions-500-series.pdf](https://www.pbgc.gov/sites/default/files/documents/instructions-500-series.pdf) (2026-10-02) |

## Glossary

- **Standard termination**: A voluntary end to a single-employer pension plan that has enough assets to pay all benefits, run under ERISA section 4041(b) and PBGC rules.

- **Lump-sum window**: A limited period in which participants may take the present value of their pension as one payment instead of waiting for monthly payments.

- **Annuity purchase**: Buying a group or individual annuity contract from an insurer so that the insurer pays participants' benefits.

- **Notice of intent to terminate**: The notice to affected parties, issued 60 to 90 days before the proposed termination date.

- **Schedule EA-S**: The certification of sufficiency in PBGC Form 500, completed by an enrolled actuary, that the plan can provide all benefits.

- **Form 501**: The post-distribution certification filed with PBGC after all plan benefits have been distributed.

- **Unfunded vested benefits**: Vested benefits not covered by plan assets. They drive the variable-rate PBGC premium, at $52 per $1,000 for 2026.

- **Missing participant**: A participant or beneficiary whom the plan administrator cannot locate. A separate PBGC program, Form MP-100 for recent terminations, governs how their benefits are handled.

## Frequently asked questions: Pension risk transfer and plan termination support

**Q: What are the steps to terminate a defined benefit plan?**

A: For a standard termination of a single-employer plan: choose a proposed termination date, issue the notice of intent to terminate 60 to 90 days before it, file Form 500 with Schedule EA-S within 180 days after it, distribute benefits after PBGC's 60-day review and file Form 501 (PBGC instructions, checked 2026-10-02).

**Q: Who signs the certification for a standard termination?**

A: An enrolled actuary completes and signs Schedule EA-S, with a narrow exception for certain plans where the plan administrator may sign. The plan administrator files the notice. Finbryn prepares the schedules for that actuary and does not file, and the engagement letter confirms who signs.

**Q: How much are PBGC premiums for 2026?**

A: For plan years beginning in 2026, single-employer plans pay a flat rate of $111 per participant and a variable rate of $52 per $1,000 of unfunded vested benefits, capped at $751 per participant. The normal due date for a calendar-year plan is October 15, 2026 (PBGC, checked 2026-10-02).

**Q: Can a plan terminate if it is underfunded?**

A: A standard termination requires enough assets to provide all benefits, and the sponsor can commit to make the plan sufficient. An underfunded plan can terminate voluntarily only in a distress termination, with different rules. A shortfall estimate before the termination date shows which route applies. Ask the plan's counsel for the legal analysis.

**Q: What is the difference between a lump-sum window and an annuity purchase?**

A: A lump-sum window pays participants the present value of their benefit in cash, calculated under section 417(e)(3) rates (August 2026 spot rates were 4.65, 5.75 and 6.73, per Notice 2026-57). An annuity purchase transfers the payments to an insurer. A plan can use both in the same termination.

**Q: What does pension plan termination support cost?**

A: It is quoted from a data sample. Drivers are participant count, data completeness, missing participants, funded status, lump sums versus annuities and scenarios priced. PBGC estimates an average of 25 hours and $5,100 to comply with its standard termination requirements, which is a burden estimate and not a provider fee. No provider range is published here.

**Q: How do I choose a pension termination or risk transfer provider?**

A: Ask who the named enrolled actuary is and confirm enrollment with the IRS, what is delivered (calculations or signed filings), who handles notices and missing participants, how data is protected and how rework is priced. Ask for a deadline calendar sample. Annuity provider selection is a fiduciary decision to make with counsel.

Related services:
- [Defined benefit freeze and DB-to-DC conversion costing](https://finbryn.com/us/services/actuarial-services/db-to-dc-conversion-plan-freeze)
- [Cash balance and defined benefit plan valuation support](https://finbryn.com/us/services/actuarial-services/cash-balance-defined-benefit-plans)
- [White-label actuarial support for accounting firms and TPAs](https://finbryn.com/us/services/actuarial-services/white-label-actuarial-support)
- [Pension asset-liability and cash flow studies](https://finbryn.com/us/services/actuarial-services/pension-asset-liability-cash-flow-studies)

Related guides:
- [Unfunded Pension Liability When Selling a Business: What Buyers Ask](https://finbryn.com/us/guides/selling-a-company-with-a-pension-or-self-funded-plan)
- [Does My Retirement Plan Need an Actuary? 401(k) to Cash Balance](https://finbryn.com/us/guides/does-my-retirement-plan-need-an-actuary)

## Sources

1. [PBGC, Standard Termination Filing Instructions (Forms 500, 501, Schedules EA-S and REP-S)](https://www.pbgc.gov/sites/default/files/documents/instructions-500-series.pdf) (2026-10-02)
2. [PBGC, Schedule EA-S: Standard Termination Certification of Sufficiency](https://www.pbgc.gov/sites/default/files/documents/500-schedule-ea-s.pdf) (2026-10-02)
3. [PBGC, Premium rates](https://www.pbgc.gov/employers-practitioners/premium-filings/rates) (2026-10-16)
4. [PBGC, Premium Filing Instructions for 2026 plan years](https://www.pbgc.gov/sites/default/files/documents/2026-premium-payment-instructions.pdf) (2026-10-02)
5. [IRS, Notice 2026-57: segment rates and yield curve](https://www.irs.gov/pub/irs-drop/n-26-57.pdf) (2026-10-02)
6. [IRS, Notice 2025-40: updated static mortality tables for 2026](https://www.irs.gov/pub/irs-drop/n-25-40.pdf) (2026-10-02)
7. [PBGC, Standard terminations](https://www.pbgc.gov/employers-practitioners/plan-terminations/standard) (2026-10-02)

Reviewed October 2026

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