- Annual Funding Notice Guidance
Field Assistance Bulletin 2025-02 provides guidance on the annual funding notice requirement changes as set forth by SECURE 2.0. - Disaster Relief for Arkansas, Tennessee, and Virginia
The IRS and PBGC have issued disaster relief in response to severe storms and flooding in Arkansas, Tennessee, and Virginia.
The Department of Labor’s Employee Benefits Security Administration issued Field Assistance Bulletin 2025-02 (the Bulletin), which provides interim guidance on the annual funding notice requirements set forth by the SECURE 2.0 Act of 2022 (SECURE 2.0).
Background
Plan sponsors of single-employer defined benefit retirement plans that are required to be insured by the Pension Benefit Guaranty Corporation (PBGC) must furnish an annual funding notice to participants, beneficiaries, and under certain circumstances to PBGC within 120 days after the close of the plan year (small plans with 100 or fewer participants have a later deadline). Generally, the funding notice provides information pertaining to the plan’s funding status, including information regarding the plan’s assets and liabilities. SECURE 2.0 made some changes to the annual funding notice for plan years beginning after December 31, 2023.
Bulletin
The Bulletin issued on April 3, 2025, provided additional guidance related to the SECURE 2.0 annual funding notice modifications as well as a new model annual funding notice. Below are highlights of this recent guidance:
- Eliminated the requirement to disclose at-risk liabilities.
- Until additional guidance is given, large plans (more than 100 participants) may rely on a reasonable, good faith estimate of the number of participants and beneficiaries for the counts required for the notice year.
- A move from the beginning-of-year funding values to year-end liability and assets.
- Allows for two safe harbor methods of determining the plan’s “average rate of return” for the plan year.
In response to severe storms and flooding in parts of Arkansas, Tennessee, and Virginia the Internal Revenue Service (IRS) and Pension Benefit Guaranty Corporation (PBGC) extended certain deadlines for individuals and businesses impacted by such events.
Impacted Areas and Dates
Individuals who reside or have a business in any of the following areas may be eligible for deadline relief:
- Arkansas – certain deadlines occurring between April 2, 2025, and November 3, 2025, are extended to November 3, 2025, to those impacted in the entire state.
- Tennessee – certain deadlines occurring between April 2, 2025, and November 3, 2025, are extended to November 3, 2025, to those impacted in the entire state.
- Virginia – certain deadlines occurring between February 10, 2025, and November 3, 2025, are extended to November 3, 2025, to Amelia, Appomattox, Bedford, Bland, and Botetourt counties; the City of Bristol; and Buchanan, Buckingham, Campbell, Carroll, Charlotte, Craig, Cumberland, Dickenson, Floyd, Franklin, Giles, Grayson, Halifax, Lee, Lunenburg, Montgomery, Nottoway, Page, Pittsylvania, Powhatan, Prince Edward, Pulaski, Rockingham, Russell, Scott, Smyth, Tazewell, Washington, Wise, and Wythe Counties.
Impacted Deadlines
Below is a partial list of retirement-impact tax filing and payment deadlines that may be extended:
- Retirement plan loan repayments may be temporarily paused under Internal Revenue Code section 72(p)(2)
- Required minimum distributions under Internal Revenue Code section 401(a)(9)
- The 10% additional income tax continues to not apply even if the following is missed during the relief period:
- Substantially equal payments made over the participant’s life or joint lives of the participant and designated beneficiary
- Deadline for using a distribution from an IRA for a first-time home purchase by the close of the 120th day after the distribution is received
- Prior tax year contribution deadlines for retirement plans
- Indirect rollover distribution deadlines
- 60-day rollovers
- Rollover of qualified loan offsets
- Refunds as a result of
- Excess deferrals
- ADP/ACP non-discrimination testing
- Eligible automatic contribution arrangement (EACA) withdrawals
- Excess IRA contributions
- Deadline for recontributing qualified reservist distributions
- Form 5500 and Form 8955-SSA filing
- Form 5948 for IRAs
- PBGC premium payments
- PBGC deadlines that are based on the Form 5500 deadline
- Single Employer Plan Termination Forms 500 and 501
Additional Resources
For any questions related to IRS deadlines and other disaster-related issues, the IRS has a toll-free number at