5 pages. Excerpt: Reduction of plan assets by credit balances. Under new ERISA section 303(f)(4), plan assets are reduced by credit balances for numerous purposes, such as at-risk determinations, benefit restrictions, and several disclosure rules (but not all disclosure rules). This erroneously treats many well-funded as underfunded based on a flawed'double-counting theory' that has previously been considered and rejected by Congress. Plan assets should be reduced by credit balances only[.]