While final details remain to be seen, the expected disclosure requirements for each plan deemed individually material for an employer will include:
- Basic plan information: name and employer ID number (EIN) of plan
- Most recent zone status as required by the Pension Protection Act (PPA)
- Whether or not a PPA rehabilitation plan or funding improvement plan applies
Contributions made to the plan for each annual period that an income statement is presented - Whether a PPA surcharge applies
- A range of collective bargaining agreement (CBA) expiration dates with significant CBAs noted
- Whether or not the employer's contribution represents more than 5% of all contributions to the plan
- Any minimum funding arrangements with the plan
If zone status were unavailable, an employer would need to disclose whether or not the plan is:
- Less than 65% funded
- Between 65% and 80% funded
- Greater than 80% funded
As noted above, these disclosures will be required for each plan deemed to be individually material to the employer's overall financial statement. For all plans that don t meet that distinction, disclosure requirements entail a summation of contributions to all plans in the aggregate. Additionally, an employer will be expected to disclose a general narrative describing each affected plan and a description of the nature and effect of any changes that could affect comparability of income statements for each period presented. This could include changes in contribution rates or covered populations.
The final standard is expected to require compliance for public entities for annual periods ending after December 15, 2011, with nonpublic entity compliance deferred one year later. With much of the information for 2011 likely already available, public companies should begin efforts to collect the necessary information now.