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What are the consequences of nullification by PBGC of a plan terminati


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Ihave a client who failed to distribute assets timely,so the PBGC nullified the termination. The request for reconsideration was denied so the nullification stands. What does this mean,especially with respect to IRS? Is the termination resolution invalidated? Is the plan considered ongoing from the original term date? If so,then it seems to me that I have to re-do the valuations,resurrect the Funding Standard Account,accrue benfits,let in new entrants,etc.?In short,treat the plan as if the termination never happened?

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May need some clarification of terms as well as timing.

Did the PBGC nullify the termination or the termination date? Was the plan also frozen? If so, then the PBGC action cannot unfreeze it.

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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