Schedule SB AFTAP (Line 15)

[Andy the Actuary]

Plan's AFTAP was determined without regard to FSCOB on 1/1/2008 and was certified as 147%. This is in accordance with IRC 436(j)(3). Instructions to completing line 15 of Schedule SB, however, indicate that AFTAP should be computed in accordance with IRC 436(j)(2) -- i.e., subtract FSCOB from assets, which in this case would be 57%. My inclination is to show 147% under the assumption that the instruction is inappropriate and than showing 57% suggest all sorts of nasty stuff applies, which don't.

Note that Schedule SB instructions indicate FTAP, line 14, are to subtract credit balances. AFTAP line 15 is not as clear.

Any thoughts?

[david rigby]

IMHO, the (j)(2) calculation is the correct one. See the second paragraph on the instructions for Line 15.

I think the (j)(3) calculation can be derived (by the IRS or anyone else) from other information on the form (sorry, no time now to look at the other entries for confirmation).