Frozen Underfunded Plan

[Dougsbpc]

A frozen underfunded defined benefit plan has met the requirements to be deemed as satisfying 401(a)(26) and the prior benefit structure test under the special exception.

One of the requirements for the exception is that the plan does not have sufficient assets to pay all benefits as evidenced by the schedule SB. The liabilities on the schedule SB can be considerably lower than what actual benefit liabilities are if all benefits were distributed (especially with a MAP election). It appears this requirement only applies to the liabilities as reflected on the schedule SB.

Anyone agree? Disagree?