val reports and AFTAP certifications

[Draper55]

year end valuatio scenario.

based on 12/31/2010 valuation 2011

aftap is certified to be 91% before 10/1/2011. at 4/1/2012

aftap is presumed to be 81%. 12/31/2011 valuation is done after 4/1 and

2011 aftap would be less than 90% if calculated and certified resulting in 2012

presumption less than 80%. Is there anythig wrong with

issuing a 2011 minimum funding report without a final 2011

aftap calculation? final 2011 aftap is done when 2011 sb is done

and contributions for 2011 have been made sufficient to have 2012

aftap above 80% so no 436 restrictions arise.

[StormShadow]

It was a little difficult to read your post because sentences were cutting off and running to the next line, so hopefully I am reading this correct...

The 2011 AFTAP you certified based on 12/31/2010 valuation is your 2011 AFTAP. Unless you need to recertify, you do not need a "final" 2011 AFTAP. Your 2011 AFTAP is 91% and you have until 10/1/2012 to certify your 2012 AFTAP (if you do not want to be subject to restrictions) - which would be based on 12/31/2011 val.

As far as issuing a funding report without an AFTAP, I don't think this is required. However, I believe there has been prior discussions as to whether a funding report is in itself an AFTAP (how about the SB?).

[Draper55]

It was a little difficult to read your post because sentences were cutting off and running to the next line, so hopefully I am reading this correct...

The 2011 AFTAP you certified based on 12/31/2010 valuation is your 2011 AFTAP. Unless you need to recertify, you do not need a "final" 2011 AFTAP. Your 2011 AFTAP is 91% and you have until 10/1/2012 to certify your 2012 AFTAP (if you do not want to be subject to restrictions) - which would be based on 12/31/2011 val.

As far as issuing a funding report without an AFTAP, I don't think this is required. However, I believe there has been prior discussions as to whether a funding report is in itself an AFTAP (how about the SB?).

i gues what you are saying is that the regulation does not go so far as to

say that any communication from the actuary to the plan administrator containing the

items necessary to calculate a revised AFTAP is in fact deemed to be a AFTAP certification.

I think the regulation did enough deeming so i like this read on it.

This approach adds some flexibility to the process whether so intended or not...thank you for

your response.

[Mike Preston]

year end valuatio scenario.

based on 12/31/2010 valuation 2011

aftap is certified to be 91% before 10/1/2011. at 4/1/2012

aftap is presumed to be 81%. 12/31/2011 valuation is done after 4/1 and

2011 aftap would be less than 90% if calculated and certified resulting in 2012

presumption less than 80%. Is there anythig wrong with

issuing a 2011 minimum funding report without a final 2011

aftap calculation? final 2011 aftap is done when 2011 sb is done

and contributions for 2011 have been made sufficient to have 2012

aftap above 80% so no 436 restrictions arise.

Storm was way too kind. The above is closer to gibberish than it is to an understandable post.

But one correction (if I, like Storm, have waded through the gibberish correctly):

The 91% certified for 2011 becomes the presumptive AFTAP for 2012 until 2012 is actually certified. The rules specifically state that you do not reduce by 10% if the number, before reduction, is 90% or more.