First Year AFTAP

[dmb]

Does adoption date of new plan come into play with regard to the first year AFTAP. E.g., New Calendar Year Plan adopted 11/1/10. 2010 AFTAP normally would be required to be certified by 10/1/10. what are due dates of certifying 2010 AFTAP in this scenario?? Thanks.

[SoCalActuary]

No real restriction issues in the first year in any event.

436d restriction applies until the benefit is funded, and then only if you granted prior service credit.

So you issue your first aftap cert in 2011 based on the 2010 funding.

[mwyatt]

Also remember the "first 5 years" rule as to applicability; otherwise it would be impossible to set up a new plan with any past service benefit.

[JBones]

No real restriction issues in the first year in any event.

436d restriction applies until the benefit is funded, and then only if you granted prior service credit.

So you issue your first aftap cert in 2011 based on the 2010 funding.

SoCal - are you saying that for a plan that is effective 1/1/2010, a 2010 AFTAP is not required? I realize that you don't have any restriction issues, but I thought I read somewhere that the AFTAP certification was still required, as pointless as it may be.

[SoCalActuary]

No real restriction issues in the first year in any event.

436d restriction applies until the benefit is funded, and then only if you granted prior service credit.

So you issue your first aftap cert in 2011 based on the 2010 funding.

SoCal - are you saying that for a plan that is effective 1/1/2010, a 2010 AFTAP is not required? I realize that you don't have any restriction issues, but I thought I read somewhere that the AFTAP certification was still required, as pointless as it may be.

You understand my assertion correctly. If no aftap is issued, the plan is restricted during the first five years from making lump sum distributions. Oh well, they didn't have any assets to pay them in any event, so no consequences for not issuing it.

In addition, common sense says that a new plan signed at the end of the year is not required to complete forms due before the plan was started.