The regs seem to indicate that a change in assumptions will put my plan out of compliance:
1/1/2008 AFTAP - > 100%
1/1/2009 AFTAP certified on 5/15/2009 <60%
No COB or PFB
I have been operating as if the plan has frozen accruals and cannot pay lump sums. There has been one person that terminated employment and could have taken a lump sum if the plan was not certified.
Plan sponsor decides to move to asset smoothing and actuary decides to change other non-mandated assumptions (ret age). 2009 AFTAP > 80%
This would be a material change since the plan operation would be impacted. In addition, it appears that if I recertify, I should have applied my new certification from 5/15. Then my plan would be out of compliance with the terms of the plan.
Does anyone see a way out of this?
