DB Annual Funding Valuations

[JAY21]

I see one brief blurb in the preamble, and in the final funding regs themselves, in section 1.430(g)-1 of the funding regs issued 10/15/2009, that "seems" to say to use the prior Rev Procs issued regarding insurance valuations for FUNDING purposes and the preamble part specifically cites Rev Proc 2005-25 and 2006-13. However, I believe those Rev Procs verbiage only deal with valuation of insurance policies for distributions.

Any thoughts out there as to whether it is clear that we should be using these 2 Rev Procs guidance for valuing insurance policies for FUNDING purposes too ? Thanks for any opinions.

[Mike Preston]

The IRS has insisted that those methods be used for funding valuations when converting 412i plans to non-412i plans.