Amending Vals, 5500, PBGC

[Penman2006]

I am just looking for some input on a problem I have. I took over a DB plan in 2007 and I have completed the 2007, 2008, and 2009 valuations, etc. The plan is a small plan with 8 participants and it's covered by the PBGC. The plan has been terminated as of 12/31/09. The plan sposnor is the client of the TPA that engaged me as the EA.

This week I was advised that there was an additional terminated vested participant that we were not aware of. The participant terminated in 2004 with a $100/mo AB payable at age 65. The participant is now age 35. Obviously everything that has been done is technically incorrect. I want to do the right thing but I do not want to needlessly have the plan spsonsor incurring fees. If I look back through the actuarial valuations, if I were to amend the valautions there would be no meaningful effect on the plan compared to what actually happened. In 2007 the sposnor contributed $15,000 more than required so maybe that credit balance would be lower by a couple of thousand at most. They never used that credit balance and and they had a $0 requirement in 2008 and 2009, and that would not have changed if the missed participant were included in those valuations. I just don't know if it's necessary to amend the vals and 5500 filings? The PBGC filings are off and those should probably be amended I feel. The Form EA-S is being amended. The plan has significant excess assets.

What would you do?

Thanks.

[Effen]

I would make sure they receive all of the proper notices related to the PBGC termination and make sure they get the benefit they are entitled to.

"woodwork" people surface all the time in bigger plans. I don't think USX is redoing Schedule Bs everytime they find a previouly unknown participant.

We have had the PBGC discover missing people on audit of a plan termination. All they request is that the missed participants receive what they are entitled to.

[david rigby]

Agree. Treat this as a data correction.

[Penman2006]

Thanks.