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Full Version: Green to critical - Amortization Extensions
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Effen
432(b)(1) ENDANGERED STATUS. --A multiemployer plan is in endangered status for a plan year if, ...

432(b)(1)(B) the plan has an accumulated funding deficiency for such plan year, or is projected to have such an accumulated funding deficiency for any of the 6 succeeding plan years, taking into account any extension of amortization periods under section 431(d).


432(b)(2) CRITICAL STATUS. --A multiemployer plan is in critical status for a plan year if,...

432(b)(2)(B)(i) the plan has an accumulated funding deficiency for the current plan year, not taking into account any extension of amortization periods under section 431(d), or


Lets say I have a plan that is "green", but has a funding deficiency approaching in 9 years. I am therefore eligible for and take the automatic 5-yr extension under Section 431(d). This extension solves my credit balance problem and I am free and clear, BUT, since I can't recognize the extension to determine if my plan is in Critical Status, I would fall into critical status 6 years from now when IGNORING the 5-yr extension I have a credit balance problem in the next 3 years.

Is that the way you all understand it?
Effen
FWIW - I have concluded that my interpretation is correct through conversations with the IRS and other actuaries.
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