Penman2006 Posted June 30, 2009 Posted June 30, 2009 Calendar year PBGC covered plan with a plan termination date of 12/31/07. The termination was submitted to the PBGC and IRS. The plan assets have not yet been distributed. Is a DOL funding notice required for 2008, and if so what do I do about the FTAP since there was no 2008 actuarial valuation required?
Andy the Actuary Posted June 30, 2009 Posted June 30, 2009 Suggest you contact Amy Viener at PBGC on this one. I found her helpful and she responds promptly. I believe she was formerly with Wm. Mercer. Viener.Amy@pbgc.gov The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
AndyH Posted July 1, 2009 Posted July 1, 2009 David? If you get an answer, would you post please? Thanks.
Penman2006 Posted July 2, 2009 Author Posted July 2, 2009 That's me. I emailed Amy at the PBGC yesterday. I will let you know if I get an answer.
AndyH Posted August 20, 2009 Posted August 20, 2009 Related question from a colleague: PBGC covered calendar year DB plan term date 03/31/08. All assets distributed May 2009. Is a 2008 AFN required? Is a 2009 AFN required? I think yes to both. Agree? David, anything else you can add to this from your discussion?
Guest Jeff Hartmann Posted August 21, 2009 Posted August 21, 2009 Calendar year PBGC covered plan with a plan termination date of 12/31/07. The termination was submitted to the PBGC and IRS. The plan assets have not yet been distributed. Is a DOL funding notice required for 2008, and if so what do I do about the FTAP since there was no 2008 actuarial valuation required? In my opinion (shared by TAG), plans that terminated before 2008 are not subject to PPA requirements such as the Annual Funding Notice. Instead, I think that plan is supposed to distribute Summary Annual Reports. ...... Jeff
Penman2006 Posted August 25, 2009 Author Posted August 25, 2009 AndyH, I did not see your post until today. I never got an answer on that question. Nobody called me back. It's a long story but luckily I was not the person that had to make the decision for the sponsor so I let it go. Reagrding your question, I think it's clear that for 2008 the AFN is required. For 2009 it sounds like everyone was paid out prior to the time the AFN would be due so you don't have any plan participants to give it to.
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