Super Max & PFEA 2004

[LIBOR]

I'm considering a re-do of a 1/1/2003 DB valuation using 90% of the weighted average 30-year Treasury to create my Supermax.

An Additional Funding Charge is avoided since my funded % is over 90% using the "gateway" rate.

Also, the lookback rules of PFEA 2004 seem to indicate that I can recalculate using weighted corporate to see if quarterlies are necessary for 2004 - the funded % is over 100% and so quarterlies are not required.

Two questions : (1) Is my read on the lookback rules correct for 2004 quarterlies ? and (2) will using the low end of the range for max purposes force me to use this same rate for some other purpose ?

Thanks in advance for your time.

[Blinky the 3-eyed Fish]

(1) Yes

(2) Yes, but I think your question focuses on your concern that by using the low-end rate in 2003, that will somehow affect you negatively in 2004? I don't see that it will since you too will be able to recompute the 2003 CL for DRC purposes in a like manner to 412(m).

[LIBOR]

That's right ! By re-working 2003 for max purposes I don't want to create charges on the minimum side that weren't there before.

As you note, we can re-calc 2003 for purposes of determining if quarterlies are necessary for 2004 ; and, the "gateway" calculation for DRC/AFC purposes is independent of the rate chosen for OBRA/RPA purposes.

I was just checking to see I've covered all the bases.

Thanks for your time and feedback !!