Regulatory and Legislative

PBGC Updates Maximum Guarantee Table for 2025

The Pension Benefit Guarantee Corporation (PBGC) has updated its table titled, “Present Value of PBGC Maximum Guarantee,” to reflect applicable values for distributions with annuity starting dates during calendar year 2025. The maximum guarantee is expressed as a dollar ceiling on the amount of the monthly benefit that may be paid to a plan participant (in the form of a life annuity beginning at age 65) by the PBGC. The maximum guarantee, which increases each year, is adjusted for benefits commencing at ages other than age 65 in order to make the maximum guarantee equivalent in value regardless of the age at which a participant starts receiving benefits from the PBGC.

The Pension Protection Act of 2006 requires that when the “adjusted funding target attainment percentage” (AFTAP) for a plan is at least 60 percent but less than 80 percent, the plan may not make a distribution in excess of the lesser of

  • 50 percent of the amount of the payment that would have been paid if the restriction did not apply, or
  • the present value, determined under guidance approved by the PBGC, of the maximum guarantee with respect to the participant under ERISA Section 4022.


The PBGC table is useful in determining the maximum payment for this purpose.

Regulatory and Legislative

IRS Releases Interim Guidance on Inadvertent Benefit Overpayments

IRS Releases Interim Guidance on Inadvertent Benefit Overpayments

The Internal Revenue Service recently issued Notice 2024-77, providing interim guidance on the treatment of “inadvertent benefit overpayments” from defined benefit and defined contribution plans as provided by Section 301 of the SECURE 2.0 Act of 2022.