dmb Posted January 7, 2015 Posted January 7, 2015 Since the passing of HATFA did not bring anything new to Annual Funding Notices, we have continued to use the original MAP-21 rates to determine the funding target for purposes of the Funding Target Attainment Percentage for the Annual Funding Notice. Since HATFA is an extension of MAP-21 we have been wondering if these amounts should be based on the HATFA rates instead. Curious to know what other are doing in this regard. Thanks.
Andy the Actuary Posted January 7, 2015 Posted January 7, 2015 Right or wrong, I used HAFTA rates because they represented the basis on which the MRC was determined. The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
david rigby Posted January 7, 2015 Posted January 7, 2015 As I read it, there was a choice for 2013, but not 2014. BTW, the IRS website no longer publishes "MAP rates" for 2014. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
dmb Posted January 7, 2015 Author Posted January 7, 2015 Thanks for the responses. So David, when you say "as I read it", what are you reading? Thanks again.
david rigby Posted January 7, 2015 Posted January 7, 2015 I'm reading HATFA. Also, see IRS Notice 2014-53 and IRS Notice 2012-61, and IRS Phone Forum 09/27/2012. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
dmb Posted January 7, 2015 Author Posted January 7, 2015 I'm not sure HATFA or 2014-53 references the Annual Funding Notice, unless you think by being an extension of MAP-21 it is implied.
david rigby Posted January 7, 2015 Posted January 7, 2015 Oh, now I see. Your "these amounts" refers to the AFN; I misread it to refer to the FTAP. w/r/t the AFN, I think the applicable guidance is DOL Field Assistance Bulletin 2013-01. (Does not change my answer. Absent any updates from the DOL, the "MAP-21 Supplement" still exists for plan years thru 2014.) I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
dmb Posted January 7, 2015 Author Posted January 7, 2015 Sorry for the confusion. So you're saying the MAP-21 Supplement amounts based on MAP-21 should be based on HATFA rates as it is for the primary part of the AFN and at least for 2014 and beyond, the original MAP-21 rates are not used for any AFN purpose (except looking back to pre-HATFA years).
My 2 cents Posted January 7, 2015 Posted January 7, 2015 It is my understanding that the funding target to be reported on the AFN itself should equal the funding target used to calculate the plan's minimum required contribution for the plan year. So while the 2013 AFN might have been based on either MAP-21 or HATFA rates, there is no alternative to having the 2014 AFN reflect the HATFA rates. To the extent that a supplement is required, it should document the differences between the non-relief funding target etc. and the information as otherwise reported on the AFN. Note that in determining the 2014 non-relief minimum contribution for the supplement, you must start with the actual amortization amounts on the relief basis carried over from 2013. If the 2013 MAP-21 (or HATFA) minimum had included no shortfall amortization, then the 2014 non-relief minimum must treat all of the unfunded funding target as a new shortfall base. Whether the disclosed 2013 non-relief minimum for last year's supplement had reflected shortfall amortization amounts is not relevant. You do not carry that forward on a parallel universe basis. The only old shortfall bases you can recognize for the supplement's 2014 non-relief minimum contribution are those used in the actual minimum required contribution (reflecting MAP-21 or HATFA) for 2013. Always check with your actuary first!
Pension RC Posted July 30, 2015 Posted July 30, 2015 Where can one find the non-relief funding segment rates for January 2014?
Andy the Actuary Posted July 30, 2015 Posted July 30, 2015 Does this link contain what you're looking for? http://www.irs.gov/Retirement-Plans/Funding-Yield-Curve-Segment-Rates The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
Calavera Posted July 30, 2015 Posted July 30, 2015 Rates also could be found at http://www.datair.com/rates.htm Just in case anybody still wondering about AFN and HATFA http://www.dol.gov/ebsa/pdf/fab2015-1.pdf
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