Deemed Burn/AFTAP Issue

[Manatee]

I've managed to confuse myself on an AFTAP/deemed burn issue. 

Plan Year = Calendar Year

Prior Year AFTAP > 100% because assets exceed funding target, so prefunding balance does not have to be subtracted from assets for AFTAP (but not FTAP) purposes.

Current Year AFTAP not certified by 4/1, so presumed AFTAP becomes last year's AFTAP minus 10%.  Presumed AFTAP is over 90%.  No deemed burn applies at this point.

Valuation is run in May.  Current year assets are less than funding target, so prefunding balance must be deducted from assets in AFTAP calculation, resulting in an AFTAP of slightly less than 80%.

Restrictions would apply, and there is enough prefunding balance so that a burn can bring AFTAP up to 80%.  Is there a required burn triggered by the actual valuation results here?

I'm thinking the answer is yes, but I haven't seen this happen in this way many times before.

Insights appreciated.

[C. B. Zeller]

This sounds right to me.

It sounds like you are already aware of this when you said "restrictions would apply," but I'll point out that the deemed reduction only applies if the plan offers a form of benefit which would be subject to the restriction on accelerated benefit payments, such as lump sum.

The deemed reduction in the prefunding balance would occur on the day that the actuary certifies the AFTAP.

[Manatee]

2 minutes ago, C. B. Zeller said:

This sounds right to me.

It sounds like you are already aware of this when you said "restrictions would apply," but I'll point out that the deemed reduction only applies if the plan offers a form of benefit which would be subject to the restriction on accelerated benefit payments, such as lump sum.

The deemed reduction in the prefunding balance would occur on the day that the actuary certifies the AFTAP.

Thank you very much.  Also yes, I was thinking of the lump sum provision.

[Mike Preston]

While no practical difference presumed AFTAP does not reduce by 10%.