Amend Schedule B?

[Guest GMP]

If you find a mistake on a previosly filed Schedule B should you amend it, as you would with a 5500, or should you, as I've recently heard argued, file just the correction as an attachment with the current B. I've always dealt with this by asking the actuary who originally signed the B to amend it. Any thoughts?

[david rigby]

Difficult to tell without more details. For example, it might be relevant how far back, magnitude of the "mistake", etc. There might be some debate (between you and the prior actuary) whether it was really a mistake. Amending a B might have a bearing on the 412 minimum contribution and/or the actual 404 deduction, or on intervening 5500's, with possbile corollary impact(s) on other issues. Therefore, analysis should not be done in a vacuum.

Also, be aware that changing assumptions is generally not permitted once the B has been filed.

[Andy the Actuary]

Difficult to tell without more details. For example, it might be relevant how far back, magnitude of the "mistake", etc. There might be some debate (between you and the prior actuary) whether it was really a mistake. Amending a B might have a bearing on the 412 minimum contribution and/or the actual 404 deduction, or on intervening 5500's, with possbile corollary impact(s) on other issues. Therefore, analysis should not be done in a vacuum.

Also, be aware that changing assumptions is generally not permitted once the B has been filed.

David, congratulations. You are now an actuary, having given the golden bromide of actuarial responses, "It depends." Jokes aside, there are a number of changes that can't be made after the Schedule B is filed. For example, changing a cost method (actually fixing) that was granted automatic approval. The first path is always back to the actuary who signed the Schedule B. If this is not possible (e.g., actuary died and left no surving actuaries), then would at least need to redo the valuation, which is interesting because the client may not be willing to pay you. In such case, walking away is an option.