PBGC missed contribution reporting

I have a client with a DB plan who has decided to delay their contribution until 1/1/2021. Since there is an unpaid minimum contribution on line 11a, how would I answer line 11b about the reporting of missed contributions to the PBGC? I cannot find anything that provides an answer.

I would probably answer "No other" and provide explanation.

At the risk of "being picky", with an extended due date of January 1, 2021, the "mailbox rule" is often used as proof of compliance with a statutory or regulatory due date: having a postmark by the date (there might be exceptions).  There are no January 1 postmarks.  If it were me advising a plan sponsor, I would point out the value of a 12/31/2020 postmark or wire transfer.

This is the explanation that we are providing on Form 5500-SF, line 11b:

[x] No.  Other.      PBGC Notification is not required yet because the Funding Deadline is January 1, 2021.”

....  Jeff

IRS Notice 2020-82, issued 11/16/2020.  https://www.irs.gov/pub/irs-drop/n-20-82.pdf .

For IRS purposes, the 1/1/2021 extended due date is now (administratively) January 4, 2021.  The PBGC may (but is not required to) follow.

7 hours ago, david rigby said:

IRS Notice 2020-82, issued 11/16/2020.  https://www.irs.gov/pub/irs-drop/n-20-82.pdf .

For IRS purposes, the 1/1/2021 extended due date is now (administratively) January 4, 2021.  The PBGC may (but is not required to) follow.

PBGC did follow with an update (recognizing January 4 contributions) to their recent Technical Update  2020-2.

....  Jeff