Reversal of prior credit balance election

[dmb]

For 2012 calendar year plan year:

Pre-MAP21 funding requirement = $40,000

MAP21 funding requirement = $0

Employer had previously elected to apply credit balance to satisfy quarterly contribution requirements.

Since funding requriement is now $0 do those credit balance elections become moot, or does employer need to formally elect to reverse those elections in order to replenish the original credit balance?

IRC 430(f)(3)(A) may apply credit balance against the minimum required contribution (not in excess of the minimum required contribution).

Based on the above, it seems that any election in excess of the minumum required contribution is moot and therefore an election to reverse the application of credit balance would not be needed. Am I not understanding correctly?

Thanks for any and all responses.

[Effen]

Not moot. The sponsor needs to formally revoke the prior elections.

From IRS Notice 2012-61:

A plan sponsor may elect to reverse all or part of any election under §1.430(f)-1(e) to reduce the plan's funding standard carryover balance or prefunding balance as of the first day of a plan year beginning in 2012 if (i) the reduction election was made on or before September 30, 2012, and (ii) the MAP 21 segment rates apply for purposes of determining the minimum required contribution for that plan year. It is expected that the regulations under §430(f) will be revised to reflect this exception to the general rule that such an election is irrevocable.