Additional Funding Relief

[dmb]

Has anyone heard that guidance regarding additional funding relief is about to be issued regarding the ability to use any of the "applicable months" that applied to the segment rates to the full yield curve as well for 2009 plan years??

[Effen]

This was posted on the COPA board today. Not sure it will help, but rumors are always fun to discuss....

From: CollegeofPensionActuaries@yahoogroups.com [mailto:CollegeofPensionActuaries@yahoogroups.com] On Behalf Of eugene l. joseph

Sent: Thursday, March 26, 2009 11:10 AM

To: CollegeofPensionActuaries@yahoogroups.com

Subject: [CollegeofPensionActuaries] Yield Curve Relief Coming in a few Days

Hi guys,

The past few months have been very stressful for me as well as for many of you; this stress has been brought on by seeing plan assets decreasing drastically (31% in some cases). And with next Wednesday, fast approaching I held out the belief that something would be done to help DB plan sponsors with the market aberration occurring during the last quarter of 2008.

In a few day, the IRS will come out: that for 2009 valuations, plans will be able to use the Yield Curve under 430(h)(2)(D) applying the applicable month concept, i.e., plans will be able to use the spot rates for September 2008, October 2008, November 2008, December 2008, and January 1, 2009. We know what those rates are for September and October 2008. So plans will get up to at least 80.

The end of the comment went like this: “When billions of dollars turn on a discrete and narrow issue, it is critical that the issue be interpreted based on the words of the statute. Now, if we could get one of these firms to say 436 should not apply to one participant plans or should have a delayed date we would be in business.

Finally, a bit of humor: I enjoy reading comments to the IRS/PBGC from the “big boys”; it usually starts with the following: “...a leading global employee benefits and human resource...” these guys get what they want.

Of course Martella and I could say we are national and international;

We small plan actuaries need to put on our collective shingles: ‘we are ACOPA leading national/international something, something.’”

I will do another post on an article in BNA yesterday, on attorneys looking into litigation on the restriction issues. I have not read this article as yet, but I am going to call BNA and see if they will email me a copy on my good looks (not a chance). So if anyone has access to BNA, please post!

Eugene