Annual Funding Notice

[ac]

Does the Annual Funding Notice replace the Summary Annual Report?

If yes, for a small plan, do we need to add the language required to waive the annual audit requirement (line 4k of the Schedule I)?

[Guest mdbarne02]

Does the Annual Funding Notice replace the Summary Annual Report?

If yes, for a small plan, do we need to add the language required to waive the annual audit requirement (line 4k of the Schedule I)?

The Annual Funding Notice replaces the Summary Annual Report ONLY if your plan is covered by the PBGC. If your plan is not covered by the PBGC, a SAR is required.

[WDIK]

Isn't the annual funding notice only required for plans covered by the PBGC?

[Blinky the 3-eyed Fish]

Isn't that what md said?

[AndyH]

To whom is it issued, participants for PBGC purposes (with benefit liabilities) or participants for DOL/IRS purposes? Real question for real floor/offset arrangement. Repeat answers permitted.

[Andy the Actuary]

Repeat answers permitted.

What about repeat questions? Two questions:

(1) What is a walking candy apple?

(2) What is a walking candy apple?

[SoCalActuary]

To whom is it issued, participants for PBGC purposes (with benefit liabilities) or participants for DOL/IRS purposes? Real question for real floor/offset arrangement. Repeat answers permitted.

I would say that employees who have met the eligibility requirements should be included in the AFN distribution, despite the fact that they have no current benefits.

[Blinky the 3-eyed Fish]

Since 101(f) says, "...each plan participant and beneficiary...", I agree with SoCal. Participant for PBGC premium determination is a specified definition that only applies for that purpose.

[SoCalActuary]

Repeat answers permitted.

What about repeat questions? Two questions:

(1) What is a walking candy apple?

(2) What is a walking candy apple?

Is this something that fell on an ant hill?

[AndyH]

Does the Annual Funding Notice replace the Summary Annual Report?

If yes, for a small plan, do we need to add the language required to waive the annual audit requirement (line 4k of the Schedule I)?

What about the second part of this question, the audit exemption? Seems to me it's a good one.

[Effen]

From posts on the ACOPA board, it seems that most people will be adding the DOL language to future AFN's. Regaring those that have already been released without it, some plan on ignoring the requirement, others plan to send out the DOL disclosure only.

Following was posted by Joan Gucciardi

From: CollegeofPensionActuaries@yahoogroups.com [mailto:CollegeofPensionActuaries@yahoogroups.com] On Behalf Of Joan Gucciardi

Sent: Thursday, August 20, 2009 1:31 PM

To: CollegeofPensionActuaries@yahoogroups.com

Subject: RE: [CollegeofPensionActuaries] AFN and Small Plan Audit Waiver

Here’s an interesting piece of news that I received from Janice Wegesin earlier this week:

“Last week you wrote me about the "audit waiver" language that should be added to the Annual Funding Notice for a small defined benefit plan.

I'm reading something from DOL (that I cannot share right now) that says that the administrator of a defined benefit plan must either provide the information to participants and beneficiaries with the AFN or as a stand-alone notification within the time a SAR would have been due and in accordance with the rules for furnishing SARs, although such plans do not have to furnish a SAR.

So, distributing it separately from the AFN is just fine, it appears.”

Joan

[AndyH]

Thanks Effen. That is a huge help.

[Andy the Actuary]

The Sungard Relius update now contains the audit exemption crud.