An underfunded plan covers only the business owner. Because the assets have been less than the present value of the accrued benefit for the last several years the prior actuary has been calculating the owner's RMD amounts based on the plan assets rather than his pure PVAB. Apparently his reasoning is that the owner will never get the PVAB, so the assets are the PVAB. In effect he's carrying the "account balance" method to the exterme. Is there any basis for this?

Me thinks you know the answer. And I'll agree with you.

If you believe in waiving benefits, this might be a good time to do so.

This dog won't hunt.

The owner's contention is synonymous to certifying no unfunded vested benefits to the PBGC because assets exceed the present value of guaranteed benefits (but not vested benefits). Similary, why not ignore the "accrual" component of the PBGC variable rate premium under the alternative calculation method when benefits are frozen. Unfortunately, our path is littered with rules that don't make sense in application but nonetheless must be followed. Sorry.

Andy, Thanks in advance for the support. This will not be a pleasant conversation.

Tymesup, the plan is to be terminated at 12/31/07, so the "waiver" can come into play there.

Mike, I didn't know they had Good Ol' Boys in California. Thanks, y'all.

Ata,

You've made it unanimous. Thank you too.