HATFA §2003(c) Amendment Deadline

[TheoDawg]

For bankrupt employers, HATFA §2003(c) generally revised IRC §436(d)(2) to provide that the AFTAP is determined without regard to the adjustment of the segment rates under IRC §430(h)(2)(C)(iv) to determine benefit restriction under §436(d)(2) . For non-collectively bargained plans, the statutory amendment deadline was the last day of the 2016 plan year with the IRS having authority to extend this deadline. Question: Has this deadline been extended by the IRS, if so, to when? Also, what is the remedial amendment period that applies here if the deadline was missed. For example, even though non-collectively bargained, would this plan be eligible for the extended remedial amendment period under Notice 2016-80, i.e., 12/31/2018.