430 Regs and American Benefits Council

[Calavera]

From a summary prepared by American Benefits Council

http://www.americanbenefitscouncil.org/doc...mmary101509.pdf

The final regulations provide some additional transition relief which could affect funding for the 2008 plan year (for example, contributions made for the 2008 plan year can be taken into account at full value without a present value discount, provided they were made by the deadline for contributions (September 15 for calendar year plans).

Do you think it's a typo and should read "contributions made for the 2007 plan year"?

[SoCalActuary]

No.

[mwyatt]

Of course, w/o digging into the regs, what exactly is the value of regs literally issued on 10/15/2009 that provide for no discount on 2008 contributions if written notification provided to the actuary by that same date? Just wondering.

[AndyH]

Members of the psychic friends network (and some insiders no doubt) had a useful option.

[Jim Norman]

Is this really any relief or anything new? Looking at the regs it seem this applies only to contributions made after a val date for a prior plan year. A 1/1/08 valuation, plan assets a/o 1/1/08 can include any 2007 PY contributions made by the deadline for 2007 funding without discount. Doesn't seem to apply to PY 2008 contributions.

[FAPInJax]

True. This was a one time shot to include 2007 contributions without having to discount them to the valuation date. It does not apply to 2008 and later contributions.