I've managed to confuse myself on an AFTAP/deemed burn issue.
Plan Year = Calendar Year
Prior Year AFTAP > 100% because assets exceed funding target, so prefunding balance does not have to be subtracted from assets for AFTAP (but not FTAP) purposes.
Current Year AFTAP not certified by 4/1, so presumed AFTAP becomes last year's AFTAP minus 10%. Presumed AFTAP is over 90%. No deemed burn applies at this point.
Valuation is run in May. Current year assets are less than funding target, so prefunding balance must be deducted from assets in AFTAP calculation, resulting in an AFTAP of slightly less than 80%.
Restrictions would apply, and there is enough prefunding balance so that a burn can bring AFTAP up to 80%. Is there a required burn triggered by the actual valuation results here?
I'm thinking the answer is yes, but I haven't seen this happen in this way many times before.
Insights appreciated.