Resumption of Accruals after AFTAP

Suppose you have a 1 participant DB that started 1/1/2016. This is a plan that actually has always been more than 100% funded.

There are no freeze consequences for the first 5 years of this plan if an AFTAP was not signed.

So that would leave plan years ending 12/31/2016, 17, 18, 19, 20 with no freeze consequences correct? But if an AFTAP was not signed before 10/1/2020, benefit accruals would be frozen starting for plan year 1/1/2021.

This particular plan will have had no signed AFTAP until 9/30/2024 and the plan will be certified at about 115%.

My understanding is that when this AFTAP is certified on 9/30/2024, benefit accruals for 2024 and 2023 will be restored.

Is there any way benefit accruals can be restored for the 2022 and 2021 years as well? Is voluntary correction available or does the participant just lose the 2021 and 2022 year accruals with no possible way to get it back?

Thanks.

What does the plan document say regarding what happens when the 436 restrictions are lifted?

Also, the plan document will state if the accruals are restored automatically or need an amendment.

With proper amendment, you can get your prior missed years back i.e. do a fresh start+future accrual.

You need to determine the mechanics of this but definitely doable.

It is good to know that it may be doable with an amendment.

Our document seems to indicate that once a current AFTAP is signed, the prior year freeze is the only year that will be automatically lifted.