first year eoy CB funding whipsaw

[abanky]

I know this was talked about before, but i couldn't find the post.

I have a Eoy CB plan where I allocate 100k, but because of PPA, I can only contribute 68k. How are people getting the funding close to the allocation amount?

[Effen]

Many people argue that the at-risk liability is equal to the sum of the cash balance accounts, therefore a contribution to bring the assets up to the at-risk liability would be deductible. However, the at-risk liability only includes vested benefits, therefore for a non-vested participant, technically you would still need to project and discount at least a few years to account for the vesting.

[Mike Preston]

For years prior to the effective date of the final regulations (2008 and 2009), I have been told that some think it is arguable as to whether the vesting percentage applies to the at-risk calculations.