MAP-21 and AFTAP

[nancy]

I have a plan that already has a certified AFTAP for 2012. In order to get the AFTAP to 80% on the original AFTAP, there was a deemed reduction in the carryover/prefunding balances. Can the plan sponsor elect to use MAP-21 on a retroactive basis and have the balances restored if the election is made by year end and a new AFTAP is signed by 12/31/12?

[Andy the Actuary]

See Notice 2012-61 A:T(3)(e)(2)

[Mike Preston]

What Andy meant to say was "yes".

His cite is correct and one should read the citation to make sure that the facts precisely fit the scenario. As described, they appear to. However, if the reduction was due to presumed AFTAP's (either less than 80% at BOY or at 4/1) then those reductions can not be reversed.