Amendment to HCEs within 2 years and 404 limit

[AndyH]

A plan was unfrozen in 2011 and benefits increased as a result. The plan covers only HCES. Per 404(o)(4), the increase in the liability must be ignored for 2 years from the later of the adoption or effective date. Assuming a calendar year, how does this timing affect in the 2013 year?

[tymesup]

IIRC, the feds think that the increase is ignored for 2013.