AFTAP Certification

[JAY21]

Any of you ASPPA D.C. conference attendees have any good insights or anything new on the AFTAP certification for 2008 distributions. I've read the ASPPA asap notice sent out a few weeks ago and a few other articles, but still would appreciate hearing anything anyone found notable or particularly interesting at the conference. Any particular session especially helpful for those of us relegated to buying the conference CDs when they're available ?

[FAPInJax]

There were a couple of good sessions BUT nothing earthshaking in news.

The biggest news was the 'range certification'. The general feeling was to avoid it unless you were guaranteed to end up in the same range once data is actually known. IF you miss the range (high or low) the choice is plan disqualification (probably having to go through EPCRS).

There was some comments regarding the timing of the certification and that actuaries may have to protect themselves from having the data to perform the certification and not providing it timely (whatever that means - although there was at least some thought as to providing the client with an engagement letter with a set timeframe)

[JAY21]

Is the AFTAP presumptions based upon a Calendar year even if the plan year is not a calendar year ? I keep seeing the deadline like April 1st at which point the presumption will be a drop of 10% in the prior year's AFTAP % for the current year. Would the April 1st be a different date if the plan year was a non-calendar year plan ?

[FAPInJax]

The regulations refer to the first day of the 4th month of the plan year. Therefore, non-calendar year plans will have their own set of dates.