New RPA Benefit Restriction Break

[Dougsbpc]

It looks like we may get a break for 2010 from freezing benefits as long as the 2008 AFTAP was at least 80%.

So for example, if you have a calendar year plan and your 2008 AFTAP was 85% and you did not get a certified AFTAP for 2009 and 2010, benefit accruals would not be frozen until 10/1/2011 unless your 2011 AFTAP was certified at 80% or more by that date. Of course the other benefit restrictions would apply.

Does anyone disagree with this?

Is there anything special that needs to be done?