AFTAP Mania

[JAY21]

OK, I can see we'll have a few clients that we won't be able to certify caledar year AFTAPs by 10/1/08.

If we certify them AFTER 10/1/08 (say certified on 10/27/08) we are "deemed" below 60% for the rest of 2008 and restricted in 2008, but we use the late 2008 AFTAP for the presumptive % for 2009 (less 10% on 4/1/09) is that correct ?

[David]

I was thinking that the plan would be under 60% until the 2009 certification is done. Let's see what others say.

[Guest RBlaine]

It says:

"In such case the presumed AFTAP of under 60% for the current plan year will continue to apply for the next plan year under 436(h)(1) until the actuary certifies the AFTAP for either the current or next plan year."

I say at 1/1/2009 the 10/27/2008 certified AFTAP is used.