Andy the Actuary

Note, it is clear that the AFN is to be distributed before the 5500 is e-filed.

Analogize from this example: We play a game with our 3 year old granddaughter. We ask, "How big is Amelia?" And then we spread out our hands and answer our own question, "So big." Let's ask a bigger question. Presumably, these calculations have been made. Why have they not been released in information form so that practitioners may begin to apprise their clients of MAP-21 impact. "So big."

Yup, it will no doubt allow my client whose Assets to FT ratio was 108% to distribute lump sums to HCEs without making additiional contributions.

Highway Bill appears to reduce required contributions so that employers will have -- at least temporarily -- the wherewithal to pay increased PBGC premiums. We must continue to count our blessings that Congress is unable to legislate changes in the Law of Gravity !!!

There were three Indian squaws. One slept on a deerskin, one slept on an elk skin and the third slept on a hippopotamus skin. All three became pregnant and the first two each had a baby boy. The one who slept on the hippopotamus skin had twin boys. This goes to prove that the squaw of the hippopotamus is equal to the sons of the squaws of the other two hides.

Not to mention, the ones with the real interest to manipulate the data have the passwords and login already any way. I've selected my first password: b@!!$&1T

Oh good grief. I just logged into EFAST2 -- first time since January 2012. It was bad enough you had to change your password quarterly, but now: Password Requirements * Must be between 8 and 16 characters long * At least 1 uppercase alpha character * At least 1 lowercase alpha character * At least 1 numeric character * At least 1 of the following special characters [!, @, #, $, %, ^, &, *, (, )] It's wonderful the government is so cautious about information that few have any interest in, is public record, and non-practitioners would have no idea how to manipulate.

Yes, my password will be taken from the Terry Southern's (aka Maxwell Kenton) 1960's Candy and will amalgamate the immortal four-letter exclamations of Bambi.

This is a welcome and necessary change given the internationally reported efforts of cyber-terrorists and other dissidents to log on to MYPPA and alter unfunded vested benefits !!! =============================================================================== Hello – This message is being sent to you because you have an online My Plan Administration Account (My PAA) account. My PAA is the web-based application used to electronically file premiums to our federal agency, the Pension Benefit Guaranty Corporation (PBGC). Federal information security regulations require us to strengthen the password requirements for My PAA. Stronger passwords will help better protect your personal and business information. Once the change takes effect (expected no later than August 1, 2012), you will be required to change your password to meet the new criteria, for example: The length of the password must be between 10 and 24 characters without any spaces. The password must contain at least 1 uppercase and 1 lowercase character. The password must contain at least 1 number and 1 special character. You will need to change your password periodically. Please note that you do not need to rush to change your password after the new rules are implemented. You may continue to access My PAA according to your normal schedule; and My PAA will prompt you to change your password at the appropriate time. Also, please notify us if you are no longer using My PAA or if you set up an account by mistake so that we can deactivate your account (after removing any plans). We thank you, in advance, for helping to keep your records up to date and secure. Please do not respond to this email. If you have any questions or requests, email them to premiums@pbgc.gov or call the practitioner toll-free number 1-800-736-2444 and select the “premium” option. My PAA Administrators Pension Benefit Guaranty Corporation (PBGC)

What you mean "we" Kimmosabe? FASB is governed by plan sponsor with blessings of auditor and you are no more than a dutiful Boy Scount. If they say "no," then you may wish to comment that doing so is not in accord with FASB as you understand it. However, you will not find the word "actuary" in FASB87.

So long as organization is on-going, in a standard termination the annuities and lump sums must provide for active participants to grow into the subsidy. See attached IRS Rev. Rule 85-6 IRS_Rev._Rul._85_6_Early_Retirement_Subsidy_Termination.PDF

PVAB increases with passage of time so that value matures to present value at normal retirement age. Increase for interest as well as survivorsip (i.e., to reflect assumed mortality that didn't occur).

The owner could make a loan to the PLLC for any reason. It would seem, however, the PLLC would still be obligated to repay the loan even though the owner received it back in the form of a qualified pension distribution. This seems more of an accounting than a pension issue.

When was this signed into law????

All of a sudden, a client has orphan participants receiving notices of their possible benefit entitlement from SSA. The Plan valuation records don't report these participants nor are Company payroll records from the 1970s and 1980s readily available if available at all. The Company wants to ensure all participants get their benefits. Is anyone aware of a process whereby a Plan Administrator may request the SSA to identify all participants listed on SSA for their plan? Best Regards, andy

Well, you can use it now. Problem may be that you've missed quarterly contributions. So, suppose election had been made before 4/15/2011, then you would be okay. There is actually an ordering principle in the final regs. that stipulates in what progression credit balance elections apply.

What happened? Form and instructions used to be but two pages !!! f5500sb__1976.pdf

Generally, what is appropriate is whatever the auditor will issue a favorable opinion. That said, how can the 24 month average represent settlement on the measurement date. Worse would be if funding using a look back month, like September. So, now you would be using a 24-month average that doesn't relate to the measurement date. In an earlier post I provided an example of a consulting firm who nevertheless advocated this position. I believe your answer is different if you're simply applying the year-end IRS yield curve which does not embody 24-month averaging.

Okay, we're in a tug of war. I read that but also read the DOL explanation: The final rule applies to covered service providers who expect at least $1,000 in compensation to be received for services to a covered plan. The final rule applies to the following covered service providers:  ERISA fiduciary service providers to a covered plan or to a “plan asset” vehicle in which such plan invests;  Investment advisers registered under Federal or State law; Record-keepers or brokers who make designated investment alternatives available to the covered plan (e.g., a “platform provider”); Providers of one or more of the following services to the covered plan who also receive “indirect compensation” in connection with such services:  Accounting, auditing, actuarial, banking, consulting, custodial, insurance, investment advisory, legal, recordkeeping, securities brokerage, third party administration, or valuation services. In short, the DOL explanation (this is a hyperlink) is more clear that this only applies to actuaries if they receive indirect compensation. Your citation, which I had seen, went in the other direction. Hence, my post.

I might add that if you don't delete the rehire, you have some active participants who will be notified by the SSA and some who won't and this inconsistency is undesirable.

Forget about the IRS Form instructions that don't answer your question. What is the form used for? To alert the SSA to notify participants they may have a benefit. So, you rehire previously reported Polly and you don't delete her from SSA. Now, Polly decides to stay beyond her death. So, Polly is still working and receives a notice from SSA about her benefit entitlement. Is this a desirable result? So, suggest you delete her. And, if I'm wrong, we can share stories in pension prison.

Clients pay my fees in one of two ways: (a) From the company account and (b) from the pension plan directly upon invoice. I receive no indirect compensation. My conclusion is that the final fee disclosure rules set forth in 2550-408b-2© do not apply to me and I'm not required to provide any disclosure. Agree or disagree?

How about you write IRS and indicate (assuming true) that client has always been a timely filer but through oversight (owing to whatever such as change in personnel), filing fell through the cracks. Ask that they forgive any penalties. This approach has not failed me in the past so long as client had a history of timely filing.

Your "win-win" reminds me of Max Von Sydow warning Robert Redford in 3 Days of the Condor that [it will end when] someday a car will pull up and a friendly face will open the door and offer you a ride.

The plan could certainly be amended to give participants -- even those who elected a life only payment form -- to get a second bite at the apple. I.e., there is but a single annuity starting date. This seems similar to the operation of the benefits restrictions on HCEs under 401(a)(4). In your case, the participant would elect lump sum payment with the understanding that monthly payments will be made until such time as the lump sum could be paid. While I'm not an attorney, sounds okay so long as the plan language is clear. Caveat: There could be problems if the Company's philosophy changes and for example, does not request the actuary to certify the AFTAP. In such case, the AFTAP defaults to less than 60% irrespective of the plan's funded status. So, the employer would then be exercising discretion that affects the special lump sum option previously elected.