PPA April Fools Day

[AndyH]

Has anyone thought up any ingenious ways of getting the 1/1/2008 funded status of all their DB plans "certified" by April 1, 2008?

Consider the regulatory ambiguities, software issues, learning curves, etc., as well as the data collection issues during FAS and 1099 season.

[Andy the Actuary]

This is a true laugher as I have clients who have not yet provided 12/31/2006 census!!!!

A thought that pains me is there may be some clients who do not want to pump up their funding so they can't pay lump sums or can only pay restricted lump sums. These clients may intentionally delay provision of census information. I wonder about the issue of employee disclosure -- the plan says you're entitled to a lump sum but we choose not fund the plan so we can pay you your lump sum. Will clients be willing to communicate this fact to their employees? What happens if they don't and employees have counted on their lump sum. My initial reaction is I don't want to be complicit in such shenanigans and it's time to retire.

[mwyatt]

Just when you finish all of your DC plans by Valentine's Day to satisfy the participant notice requirement, you can then turn to doing all of your vals by April 1 (never mind the fact that contributions made after plan year end now are "alive" for interest purposes, so you literally can't finalize your FSA until all contributions are in for the prior year)...

Will note that someone woke up w/ the electronic filing requirement for 5500s recently, which has been pushed off another 3 years. Maybe someone will reflect on the insanity of the timing issues built into PPA. That may be asking too much of politicians though.