"Is plan administrator required to notify PBGC upon realizing that plan cannot be terminated using standard termination, because it is underfunded and will be filing for bankruptcy? Client is going out of business and we've been in talks with PBGC and on track to do a standard termination (per PBGC's suggestion and also because it was possible we could fund the plan), but now we know we will be underfunded. Do we have to let PBGC know that we know for certain now we're underfunded? Proposed termination date is 7/31."

"A newly formed Cash Balance Plan has in the first year a 415(b) accrual limit of $275,000 x (1/10) = $27,500. In the second year the 415(b) accrual limit is $275,000 x (2/10) = $55,000 which is double (assuming no 415(b) $lim increase). Does the 133 1/3 accrual rule limit the second year accrual to 133 1/3 times the first year accrual?"