AFTAP reporting in year following change in val date

[JBones]

A calendar plan terminates and is paid out during 2010. The valuation date changes from EOY 2009 to BOY 2010. The 2010 AFTAP was certified based on the 2009 EOY valuation and is in excess of 100%. There would not be a material change in the AFTAP if it were recertified based on the 1/1/2010 valuation and I can see no reason why an actuary would have been required to recertify for 2010.

When filing the 2010 SB Is it correct to report the 2010 AFTAP on the Schedule SB based on the 12/31/2009 valuation? This would mean reporting the same AFTAP on 2 consecutive year's SB filings since that is the number that was reported last year.

The instructions to SB seem to suggest that they want that number to be the AFTAP based on the current year valuation results (specifically stated for non-BOY vals), but the instructions don't shed any light on how to handle this in the year after a change in valuation date.

[SoCalActuary]

JB, you did not state the plan termination date (PTD). Was it in 2009, and payout in 2010, or was the PTD in in 2010?

If 2009, then you do not maintain a 430 balance or file an SB for 2010. Otherwise, you do a 2010 val and aftap.

[JBones]

JB, you did not state the plan termination date (PTD). Was it in 2009, and payout in 2010, or was the PTD in in 2010?

If 2009, then you do not maintain a 430 balance or file an SB for 2010. Otherwise, you do a 2010 val and aftap.

Sorry, the PT date was in 2010, so a 2010 valuation is required. Are you saying that I am required to recertify my AFTAP for 2010 based on the 1/1/10 valuation even though it has already been certified based on the 12/31/09 valuation?

[SoCalActuary]

If you are performing a beginning of year valuation for 2010, then it should be no trouble to create the related aftap.

If you are performing an end of year valuation for 2010, then the 12/31/09 result would be used.

[JBones]

It isn't much trouble, I guess my only question is whether or not I am required to do so, especially if the valuation was prepared after 9/30/2010. If so, are there any issues with recertifying a 2010 AFTAP in August of 2011 after all distributions have occurred?

[Guest Quagmire]

It isn't much trouble, I guess my only question is whether or not I am required to do so, especially if the valuation was prepared after 9/30/2010. If so, are there any issues with recertifying a 2010 AFTAP in August of 2011 after all distributions have occurred?

It's not quite a recertification that is required in 2010 when the plan amendment that allows distribution takes effect, it's actually a requirement that the plan adminstrator determine whether the amendment is allowed to take effect. Although presumably this is most efficiently determined by a new AFTAP certification. See § 1.436-1(g)(5)(i)(B)