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unfunded

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  1. I believe the Schedule A information to be reported is for the contract year ending in the plan year. If the contract year ends in November, then the first Schedule A required will be for the 2019 5500.
  2. The exception for frozen plans applies only if the plan is an underfunded PBGC-covered plan or an underfunded non-top heavy plan. Whether there are HCEs in the plan is irrelevant.
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