valuation date - short CB plan year for termination

Small non-PBGC cash balance plan used a 12/31 valuation date.

Froze 3/31/20, terminated 5/31/20, assets all out on 8/12/20.  So I'm prepping final report and SB for actuary to sign ahead of 6/15 extended deadline.

Is 8/12 an okay valuation date to use?  Assets and liabilities both zero at that point since everyone was paid (final assets were just a residual dividend liquidated to pay fees).  Don't want to switch to 1/1/20 because we'd have to assume folks would be hitting 1000 hours and getting a new contribution.  5/31 valuation date would obviously require more review of the numbers the software spits out.

Thanks.

-Bri

Why can't you use a 412 D2 election? That should allow the 1 1 valuation to come up with zero cost.

Not disagreeing with Mike, but 8/12 would definitely NOT be ok.  The plan didn't exist on 8/12/20 since it was terminated on 5/31/20.  I think your val date would be 5/31.

Thanks, guys - I think we're going to go with the 1-1 date and acknowledge the amendment to eliminate the NC, just to avoid a mid-year valuation date that ties to the termination date but not the end of the short plan year.  A valuation reflecting zero benefits and assets did seem a little *too* easy!

For automatic approval it's either 1/1 or 5/31