Reversing election to reduce credit balances due to MAP-21

[dmb]

Calendar year plan, 2012 AFTAP was certified in March to 80.04%. There was a $23,000 deemed waiver of prefunding balance (there is no carryover balance) to get AFTAP to 80%, plus an additional voluntary wavier of $2,000 prefunding balance to account for the NHCE annuity purchases so the assets less prefunding would be 80% and allow employer to apply credit balance in 2013 if needed. This is not a huge issue since they still have a good amount of prefunding balance, but while it's my understanding the deemed waiver amount could be reversed if not necessary under MAP-21, can the addtional voluntary wavier be reversed as it was not done to avoid benefit restrictions?? Thanks.

[Andy the Actuary]

See Notice 2012-61 A T-2 ©