FASB Changing Disclosures by Entities Participating in Multiemployer Pension Plans


By Donald Applegarth


On July 27, 2011, the FASB announced that it had approved revisions to the proposed Accounting Standards Update (ASU), Compensation -- Retirement Benefits -- Multiemployer Plans (Subtopic 715-80): Disclosure about an Employer’s Participation in a Multiemployer Plan. The proposed ASU and the FASB’s related revisions are intended to provide more information about an employer’s financial obligations to multiemployer pension plans. Multiemployer pension plans are commonly used by an employer to provide benefits to union employees who may work for many employers during their working life, in order to enable them to accrue benefits in a single pension plan.

Currently, employers are required to disclose only their total contributions to all multiemployer plans in which they participate.

The new disclosures announced by the FASB include:

-The amount of employer contributions made to each significant plan and to all plans in the aggregate;
-An indication of whether the employer’s contributions represent more than 5% of total contributions to the plan;
-An indication of which plans, if any, are subject to a funding improvement plan;
-The expiration date(s) of collective bargaining agreement(s) and any minimum funding arrangements;
-A description of the nature and effect of any changes affecting comparability for each period in which a statement of income is presented; and
-The most recent certified funded status of the plan, as determined by the plan’s so-called “zone status,” which is required by the Pension Protection Act of 2006.

If the zone status is not available, an employer will be required to disclose whether the plan is: (a) less than 65% funded; (b) between 65% and 80% funded; or (c) greater than 80% funded.

The FASB expects that the revisions will be finalized and added to the Codification in September 2011. For public entities, the enhanced disclosures will be required in fiscal years ending after December 15, 2011. For nonpublic entities, the enhanced disclosures will be required in fiscal years ending after December 15, 2012.

This advice is not intended or written to be used for, and it cannot be used for, the purpose of avoiding any federal tax penalties that may be imposed, or for promoting, marketing or recommending to another person any tax-related matter.

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