Funding Waiver and interest charges on late quarterly contributions

[ishi]

Assume a sponsor has not, nor plans to make any quarterly contributions for a plan year. The sponsor also has asked for a funding waiver for that plan year (not granted yet). Assuming the waiver is granted, do interest charges for late quarterly contributions apply? If so, how are they calculated - i.e. when are the contributions deemed made?

The last paragraph of the answer to question 8 of Notice 89-52 seems to imply that the interest charges on late contributions do not apply if a waiver was granted. That's about all I've seen on the topic. Any thoughts are greatly appreciated.

[SoCalActuary]

Consider this:

If a waiver is granted, a special credit is issued in the funding standard account, bringing the current year cost to zero. Thus the quarterly interest is also zero.

Naturally, this logical premise starts with "If".

[david rigby]

I have done a couple of waivers where I included the interest penalty in the amount requested.

If a waiver need not include any interest penalty, that seems equivalent to granting the waiver "as of" the first quarterly due date. I see that as inconsistent with the concept of a waiver.

Might be other valid perspectives.