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Allocation of Excess Assets

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It has been a long time since I had to allocate excess assets, and I couldn't find confirmation on this point.

If a plan terminates during 2019, but doesn't allocate the excess assets until 2020, is the benefit increase attributed to the allocation of the excess treated as a benefit earned in 2019 or 2020?   


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If at the time of plan term the plan had the language needed to allocate the excess, then I would think it would be 2019.    If a post-termination amendment is needed, then I would think the amendment would specify.  It could, for example, be needed for 11-g purposes.

I don't see anything on the ACOPA board that expresses a different view, but there is not much directly on point (as you probably know).

Since the allocation technically must be tested, I don't see how treating it as a 2020 allocation makes sense.

Just one opinion.  

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