Enrolled Actuaries Meeting

[Guest Brian4]

Some information on multiemployer plans from the Enrolled Actuaries meeting:

Guidance for the Central Laborers' vs. Heinz case on suspension of benefits is expected to come out in two parts. The first part was issued after the meeting as Revenue Procedure 2005-23, with a press release and examples provided on the Treasury and IRS web sites.

The IRS discussed their anticipated approach to amortization base extensions. The letters are expected to contain a condition to address the difference in interest between the valuation interest rate and the special rate for extensions. The difference would be amortized over a period of years following each year. The period would be between one and fifteen years. The condition is the accumulated amount of these amortization amounts would be a minimum credit balance.

The IRS has issued a private letter ruling saying a particular plan cannot use contributions for service after the end of the plan year to satisfy the minimum funding requirements. This letter had not been published as of the meeting. The IRS says this letter applies only to the plan it was issued for, and has not decided whether to issue general guidance. See the American Academy of Actuaries web site for their response.

For the multiemployer funding notice that will be required under PFEA, speakers speculated that participants will be most concerned with the disclosure of the low PBGC multiemployer benefit guarantee levels.