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The treatment of credit balances under PPA has multiple issues.

436 would require a permanent release to comply with AFTAP. But it only gets invoked if the actuary has done the AFTAP certification.

430 depends on the election to use or keep the COB. How much is a decision for the employer.

Quarterly payments require burning of the COB. But if so, how does that election affect the 430 minimums?

I am looking for a more recent article than the excellent Buck article reported on BenefitsLink last November.

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