Annual Funding Notice $50 Million or Not?

[Just Me]

Underfunded amount is more than $50 million on "regular" basis, but less than $50 million on MAP-21 basis. Is this over the $50 million threshhold for providing a copy of the AFN to the PBGC or not?

[Hojo]

MAP-21 is the funding basis so you are not underfunded by more than $50 million. Don't try to make it more difficult than it needs to be.

[Just Me]

We spoke with the PBGC directly. They indicated that there is simply no guidance regarding whether the MAP-21 numbers can be used to determine the $50 million threshold. They suggested that perhaps the DOL has an informal opinion.