If you participate in multiemployer plans, the disclosure requirements will require you to coordinate with the unions or the trustee of the plans to obtain the relevant information needed for the required disclosures. We strongly encourage you to reach out to these institutions and notify them on the information you will need, as this information may take time to obtain. Listed below are the key required disclosures for multiemployer plans. Reach out to your auditors for any other disclosures that may be necessary for your company.
The new disclosures requirements are as follows:
- For individually material plans:
- Plan legal name and Employer Identification Number.
- Most recent certified funded status, expressed as a “zone status,” as required by the Pension Protection Act of 2006. If zone status is not available, an employer should disclose whether the plan was less than 65 percent funded, between 65 percent and 80 percent funded, or greater than 80 percent funded.
- Expiration date(s) of collective bargaining agreement(s) and any minimum funding arrangements.
- Indication of whether the employer’s contributions represent more than 5 percent of total contributions to the plan.
- Indication of what plans, if any, are subject to a funding improvement plan.
- Contributions made to each individually material plan and to the total contributions made to all other plans in the aggregate.
- A description of the nature and effect of any changes affecting comparability from period to period for each period in which statement of income is presented.
What’s Next?
For non-public entities, the disclosures will be required for annual periods in fiscal years ending after December 15, 2012.