Funding Improvement Plan - MPRA changes to funding benchmarks

[Miner88]

The MPRA changed the definition of "funding improvement plan" to require that the plan's funding percentage at the close of the funding improvement period equal or exceed the sum of (i) such percentage at the beginning of the first plan year for which the plan is certified to be in endangered status, plus (ii) 33% of the difference between 100% and the percentage in (i).

Prior to MPRA, clause (i) was the plan's funded percentage at the beginning of the funding improvement period.

Does this mean that plans that are half way through their funding improvement period need to comply with the new target? Or is this just for new funding improvement plans? In our situation, this change causes the plan to have a significantly higher funding target.

Any thoughts?

[27alexander]

I am looking into the same question and have thus far not been able to find any guidance regarding whether the new rules under MPRA Section 105 for determining the target funding percentage should apply to FIPs already in effect prior to 12/31/2014.

There are other provisions of MPRA with the same effective date that would appear to apply to FIPs (or adoption periods) in effect prior to such date.

In the absence of a clear provision in Section 105 excepting plans with FIPs commencing before 12/31/2015, I am inclined to say that existing FIPs need to be updated to comply with the new rules. For many plans, such as yours, the stakes are high for how this question turns.

Any thoughts or insights from the community would be appreciated.