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Hi all

My apologies if this was discussed before.

The normal 5500 filing was due by 4/30/2020 which was automatically extended to 7/15/2020 (if 5558 was filed, would have been the same deadline).

What is the deadline to certify AFTAP 6/30/2020 or 7/15/2020?

Have a great weekend and be safe.

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CARES Act waived the requirement to certify an AFTAP for any plan years beginning or ending in 2020.

However, if you wanted to certify one anyway, because maybe your 2020 AFTAP would be materially higher than your 2019 AFTAP, then I do not believe the due date would be extended.

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Agreed on the non extension. I still want to do it because I have no idea what future adjustments IRS will come up with once all Covid19 issues go away. Old school approach.

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7 hours ago, C. B. Zeller said:

CARES Act waived the requirement to certify an AFTAP for any plan years beginning or ending in 2020.

However, if you wanted to certify one anyway, because maybe your 2020 AFTAP would be materially higher than your 2019 AFTAP, then I do not believe the due date would be extended.

CARES Act says "......  a plan sponsor may ELECT ...... "(to use the AFTAP for plan year ending in 2019).   I don't believe that AFTAP certification has been "waived" if there is no such election made.

Absent any election, I think that June 30, 2020 is your AFTAP deadline.  I think it would be risky to wait until AFTER June 30 to certify AFTAP or make the election to use prior AFTAP.

.....  Jeff

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Hi Jeff, 100% in agreement with you and everyone else. Thank you for your input.

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4 hours ago, Jeff Hartmann said:

CARES Act says "......  a plan sponsor may ELECT ...... "(to use the AFTAP for plan year ending in 2019).   I don't believe that AFTAP certification has been "waived" if there is no such election made.

Agreed, my use of the term "waived" was sloppy language. I apologize.

As of yet there is no guidance specifying a method for making the election, nor a deadline to do so. Presumably the sponsor could make the election even after the 1st day of the 10th month of the plan year and still have it apply.

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18 hours ago, C. B. Zeller said:

Agreed, my use of the term "waived" was sloppy language. I apologize.

As of yet there is no guidance specifying a method for making the election, nor a deadline to do so. Presumably the sponsor could make the election even after the 1st day of the 10th month of the plan year and still have it apply.

What else is new  :)      "As of yet there is no guidance   ........  "

In the absence of guidance, I drafted my own simple Election Form for a few of my plans that otherwise would have decreased their AFTAP 10%, below 80%, on April 1, 2020 .... to avoid the requirement to send Benefit Restriction Notices in April  (not withstanding possible Notice relief given by DOL on the day that AFN's were due).  In my election form, I made the election automatically "revoked" if the Actuary issues a subsequent 2020 AFTAP.  I hope "guidance" does not prohibit doing that.

....  Jeff

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Lack of guidance and uncertainty of "if and when" it will be provided is a good reason to get it done timely.

Thank you all

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