Cash Balance Off-set Plan Participant Count

[vrradjew]

There is a cash balance off-set plan with a participant count of 32 before the offset. After the offset, there is only one participant receiving a benefit under the cash balance side of the plan. When counting participants for the PBGC flat-rate premium, would we use the number of participants receiving a benefit before or after the offset?

[Calavera]

For PBGC purposes only count those who have any associated plan liability (i.e. after offset).