carrots

I love it! Great idea!

After the 9/15 contribution deadline calculations, and after the 9/30 AFTAP deadline work, and after the 10/15 Form 5500 deadlines, what should I do next?

Gary: I'd look at AAA, FASB and GAAP guidelines.

Why not just give a statement every year?

Ditto to SoCal and Scott

Isn't this a case of "only if you want the plan to pay them"?

If you are just updating the plan's definition of actuarial equivalence (rather than the special 417(e) assumptions), I believe that you just need to protect (grandfather) the PVAB as of the later of the effective date of the amendment or the date the amendment was signed.

Am I correct that we do not have regs for 2009 AFTAPs for plans with EOY valuations? If so, do we just do the same as we did for 2008: use the previous 12/31 values and adjust appropriately?

Assuming a calendar year plan, with an EOY valuation, and a very large COB: Assume there is a deemed reduction in COB in 2008 in order to have an 80% AFTAP. If the 2009 AFTAP is not certified by 3/31/2009 (or, even by 9/30/2009), I believe that there would be another deemed reduction to again get an 80% AFTAP, avoiding the presumed underfunding of 436(h). Does this seem like a correct reading of 436(f)(3) and 436(h)?

Presumably, they will file for a standard termination with the PBGC. The 2008 contribution should only be the 7 year ammortization of the Funding Shortfall (no TNC). Can they take a loan from the plan to pay that? After the PBGC approval, it makes absolutely no sense whatsoever to not pay the rank and file - in fact they are required to pay the benefits within 180 days (I think). Then, distribute the remainder to the owners. I wouldn't let a poorly thought out and worded law get in the way of doing what is obviously right. Okay, shoot me down.

Assuming that the business has been paying the investment, consulting, and admin fees, can the plan reimburse the business for those fees - perhaps going back many years?

The way I view it is that you have a method for determining the salary (current year) and, if you change that method (to prior years salary and a salary increase factor), you are now using a new method. But, I can understand someone saying that you are are just changing the salary assumption!

Gary, also the large increase in AB will fall into the FT, rather than the TNC, so that it can be amortized over 7 years. You may need to watch the AFTAP.

The proposed reg on approval for changes in funding method is 1.430(d)-1(g)(3)

It would be a change in funding method, but I think that is okay since it is the first year for PPA06.

If the valuation date is 8/1/2008, the TNC is based upon the expected increase in AB during 8/1/2008-7/31/2009 plan year. What did you expect, as of 8/1/2008? Did you, for example, expect that the salary would not increase or, perhaps, that the participant would not work enough hours to accrue an increase in AB? Could the TNC, based upon an expected $0 increase in AB, be $0?

Can I, as the Enrolled Actuary, choose to keep the prefunding balance at $0, simply by entering $0 in line 11d of the Schedule SB? Thus avoiding the need for a sponsor election.

Does anyone know when the new, promised PPA regs (300+ pages?) will be released?

Is there any chance that, as of 1/1/2008, you could justify an actuarial assumption that no benefits will accrue during 2008? For example, could you assume that the client will have a bad year and that no one will earn a year of credited service? That would result in a $0 TNC.

Unfortunately, a number of years ago, one Schedule B became critical in a law suit. A possible error in one of the entries (the case was settled without a ruling) was used to cause a lot of trouble.

As far as I can tell, for 2008, this attachment is required along with a whole bundle of others. The number of attachments, particularly for small plans, seems to be completely out of control!

There is only one set of requirements for qualification as an EA. If the EA also gives opinions in other (non-EA) areas of work, the EA should separately meet those requirements.

Then in 1.410(b)-9. Thanks, Kevin!

Is there any difference between a "Former HCE" referenced in Reg. 1.401(a)(4)-5(b)(3)(ii) (Restricted Employee Defined) and a "Highly Compensated Former Employee" defined in Reg. 1.414(q)-1T, A-4 and IRS Notice 97-45 (for purposes of IRC 414(q)(6))? The answer I want is that a "Former HCE" is the same as a "HC Former E!" Thanks!

What interest rate should be used to "adjust the amount reported in line 13, column (a)" from 1/1/2008 to 12/31/2008? The effective rate, for the plan I am working on, is based on November, 2008 segment rates.