Segment Rates for 1/1/2009 small DB valuation

[carrots]

For 1/1/2009 valuations, most of my small DB plans would "normally" use the September, 2008 transitional segment rates of 5.41%, 6.09% and 6.41% (for the 1/1/2008 valuations, we typically used the September, 2007 transitional segment rates of 5.66%, 5.85%, and 6.03%).

What options, if any, does the IRS's March 31, 2009 Special Edition of Employee Plan News give us to use different rates?

For example, could we use the October, 2008 spot rates of 7.35%, 8.61% and 7.26%?

[Andy the Actuary]

My read and observing discussions at the 2009 EA meeting among JH et al, meant you could for 2009 (not 2008) change your interest rate selection for 2009 and thereafter to either the segment rates, segment transitional rates, or yield curve for either the month containing the valuation date or any of the four preceding months. This change can be made with automatic approval. This change is for funding and 436 purposes. You would need to read the PBGC language to see if such change flows through if you had chosen to use the "alternate funding target" to compute unfunded vested benefits in 2008. This may be difficult to conclude since nothing specific has yet to be issued.