AFTAP for 12/31 Plan Year

[nancy]

If a Plan Year begins 12/31/11 when must the 2011 AFTAP be signed? September 1, September 30 or October 1?

[Andy the Actuary]

So, the question is what does "by the first day of the 10th month of the current plan year" mean?

Plan Year begins 12/31/2011. Thus, first month of the plan year begins 12/31/2011, and 10th month of the plan year begins 9/30/2012 (because there is no 9/31/2012). So, we're looking at either 9/30/2012 or 9/29/2012 depending upon whether "by the" includes the first day of the 10th month. IMHO, "by" means no later than 9/29/2012 -- the day before -- just as for a calendar year plan, we were all scrambling to get our certifications done so they were dated on or before 9/30/2012.