Watch It, Gotcha

[Andy the Actuary]

Mr. Rigby was kind enough to point out that their are PPA act sections that for some reason were not included in the revisons to the IRC and were not noted in WRERA. Act Section 115, for example, provides relaxed transition (e.g., 90% rather than 92% of FT in 2008; 92% rather then 94% in 2009; etc.) under certain circumstances for employers engaged in interurban or interstate public bus transportation. You will not find reference to this treatment in IRC Sec. 430©(5). Not a biggie unless your client just happens to be one of the affected employers.

The point is not to get too comfortable relying just on the IRC and regulations. It also begs the question of whether or not the act should be followed to the extent it has not been codified in the IRC. Clearly, technical corrections should address this.

[Blinky the 3-eyed Fish]

I had to review another actuary's work for an interstate transit company. I thought the actuary was making up the late quarterly exception for such companies, but I pressed on searching for the truth and finally found it. I learned this fact the hard way.

[Andy the Actuary]

When an actuary speaks, I listen carefully and never discount what he's saying. That is, of course, unless I'm looking in the mirror.