Reportable Event -- Second Year

[Andy the Actuary]

A DB Plan has over 1M in unfunded vested benefits (funded %=77%) as of 1/1/2011 and the variable premium applies.

Active Plan Participation is as follows:

1/1/2009 50

1/1/2010 30

1/1/2011 30

PBGC Form 10 was filed in 2010 for the active participation in 2009. Since active participation 1/1/2011 is less 75% of active participation as of 1/1/2009, must Form 10 be filed for 2010?

[SoCalActuary]

Yes, you should file Form 10.

[Andy the Actuary]

Yes, you should file Form 10.

Thank you. That was my answer but I was hoping for a "no."