Frozen prior to September 2005 no aftap restrictions

Hi,

As per 1.436-1(d)(4) a plan that was frozen plan prior to 9/1/2005 is not subject to the AFTAP Restrictions including that it can pay lump sums. If the AFTAP calculations are above 100%, however, there were no actual AFTAP certifications done, is there any basis for the SB to show the AFTAP as being above 100% and it will be based on the signing of the SB (since there are no AFTAP restrictions) or must the SB show the AFTAP as 60% ?

As why file with 60% and possibly draw attention of the electronic system, if there are really no AFTAP restrictions for this plan anyway?

Thank you

The instructions for schedule SB line 15:

Quote

If no AFTAP was certified for the plan year, attach an explanation and (1) report 100%, if the plan's adjusted funding target for the plan year is zero, as described in section 1.436- 1(j)(1)(iv) of the Treasury regulations, or (2) leave line 15 blank if the plan's adjusted funding target for the plan year is not equal to zero. Label the attachment, "Line 15, Reconciliation of differences between valuation results and amounts used to calculate AFTAP.”

Personally, I usually find it simpler to certify an AFTAP (even if it's not needed) than to create an attachment to the SB.

Thank you C.B. Zeller. Just another question , please....Line 15 will be left blank and an attachment will be  included that explains that the AFTAP per the val is 105%, however, since the AFTAP was not certified, it is deemed to be 59%. However, since this plan was frozen prior to September 2005, there are no AFTAP restrictions." ...1. Does leaving line 15 blank draw attention...ie the efast might have certain things to look for as flags. As, since this plan was frozen prior to 9 2005 is there a way to file that it should not attract attention? As an AFTAP of 59% for this plan has no bearing in reality on this plan. Thank you for any thoughts.