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ARP Modifications to Annual Funding Notice


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Has there been any guidance released relating to if or how the Annual Funding Notice should be modified to reflect the funding relief of the American Rescue Plan? I think the interest rate changes shouldn't be a big deal given the guidance from when MAP-21 was released, but should we attempt to demonstrate the impact on the MRC of the change from a 7-year to 15-year amortization period, along with an amortization fresh start?

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The MAP-21 disclosures were due to the discretionary nature of the adopted relief.(If I remember my AFN logic correctly, the additional disclosure was only if MAP rates were used before HAFTA)  If ARP is likewise discretionary i would include a similar comparison; but if it's mandatory then what good does it due to disclose a what if that can't be?

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  • 2 weeks later...

I saw something that the old 2020 expiration date for the HATFA disclosure was just updated to 2034 for the ARPA impact.

Since 2022 is the required start for the 15-year amort, and my plan didn't have a 2021 stabilized shortfall, I'm thern doing my unstabilized MRC based on 7-year because it's all hypothetical, indeed.

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