AFTAP and -11(g) Amendments

[Guest merlin]

How does a plan's AFTAP affect the ability to fix a coverage or nondiscrimination failure by means of a corrective amendment under -11(g)? I think:

1. For a BOY valuation AFTAP (<= 80%, but not < 60%) has no effect, since the additional benefit is accrued at EOY, causing no increase in the FT as of the beginning of the year. Agree? Disagree?

2. For an EOY valuation the FT, assuming the AFTAP can be calculated @ EOY, the increase in the AFTAP would have to be fully funded to >=80%. If AFTAP can be calc'd at EOY-1, then same answer as 1 above?

What if AFTAP is <60%? Same reasoning in each insatnce?

[ak2ary]

AFTAP is based on the accrued benefit at the beginning of the year regardless of whether its a BOY or EOY val, so unless the amendment has a past service liability that extends past the beginning of the year its not in AFTAP for year 1

But it does effect AFTAP for year 2 if its adopted in year 2 but provides for benefits in year 1 and its not at all clear what the impact on the Year 2 AFTAP has on the ability of the amendment to take effect for year 1