Annual Funding Notices - EOY vals

[Effen]

Just looking for consensus since I don't believe we have any real guidance, but how are people doing the AFN for an EOY val?

The instructions seem to call for the AFN to report the FTAP for the year which the notice relates. So lets say we are doing the 2008 AFN. In the Funding Target Attainment Percentage section do you report the 12/31/2007 numbers (which we used to determine the 2008 AFTAP) or would we show the 12/31/2008 numbers (which would really be for the 2009 AFTAP).

Or would you show both 12/31/2007 and 12/31/2008 as two of the three year's of history?

[Effen]

Not sure how to take the lack of responses on this, maybe its just a stupid question?

Anyway, what we decided to do was show the 12/31/2007 values in the 3-yr history part of the schedule. 12/31/2007 liabilities and assets, including 2007 NC and 2007 contributions (and receivables). This seemed like the closest thing to the "2008 FTAP".

The transition numbers below the schedule will be 12/31/07 & 12/31/06 (EOY values of BOY assets and liabilities - ie. No NC or contributions). I know, doesn't make much sense, but it was easy.

The stuff at the end of notice will be 12/31/2008 assets (including receivables) and liabilities (including 2008 TNC). We are not revaluting 12/31/08 liabilities at PBGC rate since we used the exception for small plans and determined the variable rate premium based on funding target.

Anyone see any major flaws in any of that?