adjusting plan assets for funding defiicency Minimum funding for plans with with prior year FD

[VeryOldMan]

Before PPA a late contribution creating a FD for a plan year was added to the plan assets for the following year funding computations.  Not clear as how  PPA changed this rule?

I have a pension plan that had a funding deficiency (FD) in 2018 plan year due to a late contribution of $30,000, which was deposited in Dec 2019. For the 2019 plan year the valuation date is changed from EOY to BOY. Under 4(A)(ii),  should the late contribution be included as a plan asset for funding purposes for 2019? SB instructions say not to include  such contributions in line 2(a) [ market value of assets] or 2(b) [Actuarial Value of plan assets]. 

[Effen]

No, you don't get to count it. 

Yes, it is a "double whammy".  you don't get credit in the assets so your 2019 MRC is higher, and the unpaid minimum amount is still due. 

 

[VeryOldMan]

Thanks, after further review and working it out, I see that you are correct.