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HATFA modified the benchmark for applying Section 436 restrictions when the sponsor is bankrupt. Starting in 2015, to pay accelerated benefits in a plan sponsored by a company in bankruptcy, the AFTAP must be certified as at least 100% based on non-relief segment rates. Here are two or three questions (assume that the sponsor is in bankruptcy and that the plan year is the calendar year): 1. To what extent would the 2014 AFTAP as certified continue to apply between 1/1/15 and 3/31/15? Is there any carryover for that period, or must there be a fresh 2015 AFTAP certification (range or otherwise) to justify payment in 2015 of any accelerated benefits? Would it matter if the enrolled actuary is willing to certify that the 2014 AFTAP, determined without regard to the relief segment rates, would have been 100%, or must a certification using 2015 assets and 2015 liabilities be issued? 2. Suppose that the PBGC has decided to take over the plan based on a plan termination date in 2014 related to the corporate bankruptcy filing. Would the plan's limitation status for 2014 become permanent because the plan terminated before 2015 (i.e., given that the AFTAP for 2014 was certified as being at least 100%, would IRC Section 436 never become applicable, notwithstanding the fact that in 2014 the non-relief AFTAP would have been lower than 100%)? Would it matter if the retroactive termination date chosen by the PBGC is earlier than the date (prior to October 1, 2014) on which the 2014 AFTAP was certified by the enrolled actuary? Any thoughts concerning these issues would be welcome.