Funding Notices

[Effen]

Would anyone be willing to share what kind of cover letter they are planning to attach to the new Funding Notices that need to go out this year for multiemployer plans?

The notice requires disclosure of the funded ratio based on RPA Current Liability and Actuarial Value of Assets. This can be terribly misleading, especially in the multi-employer area.

I was planning on attaching a cover letter explaining that the notice can be misleading, that it is required, and stating the funded ratios based on market value and a more reasonable interest assumption. I assume that others aren't just sending the notice out blind, and was hoping someone might want to share how they handled it.

[Guest trudyhorn]

I was told last week by an Actuary that a cover letter CANNOT accompany the PFEA notice, as the regs imply that it might dilute the message. He is going to review this again to see if we can append additional wording to the notice. Does anyone have different information on this?

[Effen]

I agree that you can't dilute the message, but 2520.101-4(b)(8) clearly states that you are permitted to provide additional information that is helpful to understanding the mandatory information.