Now that the OBRA FFL is gone, what happens to the prior OBRA FFL bases? Do we continue to maintain them?

Also, suppose if the plan hit OBRA limit in 2003, should an OBRA base be established in 2004?

IMHO, existing bases should continue, and you should establish a new base at 2004 if applicable. This is the only thing in the Gray Book:

Gray Book Q&A 2004-1
Funding: Maintenance of OBRA Full Funding Bases
With the repeal of the OBRA full funding limit, are there any special rules for handling the amortization of any existing OBRA full funding limit amortization bases in the 2004 valuation, or should they simply continue to be amortized over the remaining period(s)?

RESPONSE
There are no special rules. They should continue to be amortized over the remaining period(s) until they are fully amortized or wiped out by a full funding credit, whichever happens sooner.

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