Valuation date change - from eoy to boy

Hi, I am new to this posting board and skimmed  this topic that may have been already been discussed.

We are considering a change in valuation date from 12/31/2019 to 1/1/2019. I haven't checked IRS Revenue Procedure on funding method changes and whether it is eligible for automatic approval, however, one major drawback to this proposed change is that AFTAP certification deadline would have been 9/30/2019 and since this didn't happen then the plan is automatically frozen 10/1/2019 among other adverse operational changes. If they already received credited service for benefit accrual for the period 1/1/2019 to 9/30/2019 then for 2019 the automatic benefit freeze doesn't affect 1/1/2019 funding valuation results right ?

I am replying to my question cause I was a bit lazy originally.  Use this posting instead of the earlier one.

Hi, I am new to this posting board and skimmed  this topic that may have been already been discussed.

We are considering a change in valuation date from 12/31/2019 to 1/1/2019. I haven't checked IRS Revenue Procedure on funding method changes and whether it is eligible for automatic approval, however, one major drawback to this proposed change is that AFTAP certification deadline would have been 9/30/2019 and since this didn't happen then the plan is automatically frozen 10/1/2019 among other adverse operational changes. If they already received credited service for benefit accrual for the period 1/1/2019 to 9/30/2019 then for 2019 the automatic benefit freeze doesn't affect 1/1/2019 funding valuation results right ?

If we certify AFTAP, say 7/15/2020 to be over 80% for the 1/1/2019 valuation, then the automatic benefit freeze is 'lifted' effective 1/1/2019, right ?  The hope is to keep accruals ongoing for 2019 and 2020 plan years. Plan year is 1/1. Let's also say plan operations experienced during the stub period  is unaffected.

The 2019 AFTAP had to have been certified by 9/30/2019. It would have been based on the funding results for the 12/31/2018 valuation. You do not have to re-certify merely because of a change in the funding method to use the first day of the year as the valuation date, unless the AFTAP measured as of 1/1/2019 would be materially different from the already-certified AFTAP.

Rev. Proc. 2017-56 provides automatic approval for a change in the valuation date to the first day of the year. Check section 6 for restrictions on its applicability.