Generally, my understanding is that the RPA '94 CL is the pvab on a termination basis using prescribed interest and mortality and all other funding assumptions.

Now let's say we are valuaing a 1 participant plan and the NRA is 55 and the ARA is say 60 (i.e. participant is to work past NRA and not receive pension until ARA).

Therefore, Sch B will have ARA as 60.

The question is:
What ARA to use for CL for PBGC premium purposes, 404 and 412 purposes?

If CL is supposed to be on a plan term basis one would think that an ARA age greater than NRA is unreasonable.

However, CL requires that you use funding assumptions w/r/t ARA, which is after NRA.

Bottom line, is it reasonable to use ARA higher than NRA for CL and for PBGC?

It seems ok to use ARA greater than NRA for funding if participant intends to work beyond NRA and not receive pension until actual ret. Of course the participant is suspending his pension as required.

Thanks.

I think the regulations define CL as the present value of all benefits accrued to date, not the "plan termination liability". If you are making an assumption that participants will retire at an age greater than NRA then that is what the CL pvab will be based on/discounted from. Large plan valuations typically use retirement rates. In that case a given particpant would have pieces of his benefit discounted from the variuos retirement ages, some of which would be after NRA. I don't see the difference, it's just that you are assuming 100% of the participant retires at age 60 (past NRD).

Regarding the PBGC liability, the Schedule A says right on the form "assumed retirement age". (I'm assuming it's not really a one man plan since no PBGC filing would be required.)