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Annual Funding Notice - When Due?


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See Q&A1 in DOL Field Assistance Bulletin 2009-01

http://www.dol.gov/ebsa/regs/fabmain.html

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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My understanding is that a small plan with a calendar year plan year would have had to distribute the 2009 annual funding notice by October 15, 2010. No extra 30 days. In effect, the plan already got nearly a year and a half extra time (compared with a larger plan, which would have had to distribute the notices by April 30, 2009).

Given that the absolute latest day that a contribution could have been made was September 15, 2010, even plans with end of year valuations should have been able to complete the preparation and distribution of the notices by October 15th.

Always check with your actuary first!

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My understanding is that a small plan with a calendar year plan year would have had to distribute the 2009 annual funding notice by October 15, 2010. No extra 30 days. In effect, the plan already got nearly a year and a half extra time (compared with a larger plan, which would have had to distribute the notices by April 30, 2009).

No, the due date for distributing the 2009 AFN for larger plans is/was April 28, 2010.

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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OK, you're right about April 2010, so it's just a half year advantage for the small plans. I think I was confused by the PBGC premium small plan vs large plan due date thing.

But where did you get April 28th? 31 days in January plus 28 in February plus 31 days in March plus 30 days in April = 120 days, and we didn't have to deal with either leap year day or April 30 being on a weekend this year.

The key fact being that the small plan AFNs were due a week ago.

Always check with your actuary first!

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But where did you get April 28th?

You're correct. My booboo.

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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Small plans: 2009 annual funding notice is due on the date that the 2009 5500 filing is due. Large plans have a shorter timeframe (120 days after end of relevant year, so 2009 AFNs for large plans had to be distributed by 4/30/10).

Always check with your actuary first!

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Small plans: 2009 annual funding notice is due on the date that the 2009 5500 filing is due. Large plans have a shorter timeframe (120 days after end of relevant year, so 2009 AFNs for large plans had to be distributed by 4/30/10).

I thought for small plans it was the filing date, not the filing due date, no?

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I thought for small plans it was the filing date, not the filing due date, no?

It's the earlier of the actual filing date or the due date.

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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See Q&A1 in DOL Field Assistance Bulletin 2009-01

http://www.dol.gov/ebsa/regs/fabmain.html

So no relation at all to the filing of the 5500. We just filed the 2009 5500 and I think we sent an Annual Funding Notice earlier this spring. So that one covered what year(s)? Don't they report 3 years? I'll have to look in the morning.

The notice we sent in the spring showed info for 2008, 2007, and 2006. Was that the 2008 or 2009 notice? And what was the due date?

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The notice we sent in the spring showed info for 2008, 2007, and 2006. Was that the 2008 or 2009 notice? And what was the due date?

Did you read the posts and/or the FAB?

As stated above, the AFN for the 2008 PY was sent in 2009; the AFN for the 2009 PY was sent in 2010. Etc.

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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The notice we sent in the spring showed info for 2008, 2007, and 2006. Was that the 2008 or 2009 notice? And what was the due date?

Did you read the posts and/or the FAB?

As stated above, the AFN for the 2008 PY was sent in 2009; the AFN for the 2009 PY was sent in 2010. Etc.

Yeah both, but I'm old and slow. Just struggling a bit with the nomenclature.

"AFN for the 2008 plan year" and "2009 AFN" are not synonyms then?

In the Army we would have just painted it green and been done.

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