Annual Funding Notice for a Terminated DB Plan

[Guest NPS Darren]

I have a DB plan with a termination date of 12/31/07, because of many reasons, including not hearing from the IRS, the plan still had assets as of 12/31/08. Must I prepare an Annual Funding Notice instead of a Summary Annual Report? If so, any ideas how I do that without a valuation report?

[Effen]

I don't know if there is a real answer, but we took the position that we were only going to prepare the old SAR type notice. Primarily because the plan terminated in 2007 and therefore we did not prepare a 2008 SB. Since we didn't prepare an SB, we don't have any of the information to put in the new AFN.

I figured this was a good faith effort.