FDL for underfunded church plan?

[Guest Dionysius]

Client wants to terminate an underfunded non-electing church DB plan. I was going to recommend that the client submit a 5310 FDL application, since the most recent FDL is from the 1980's. But will the IRS refuse to issue a favorable letter because of the underfunding? The plan is exempt from Title IV but I'm wondering if there's anything in the pre-ERISA qualification rules that the IRS might hang its hat on to require full funding as a condition for a favorable letter.

[Guest habika]

edited to remove marketing link