What is the AFTAP for a new plan in 2007 with no past service liability and a beginning of year val date? 100%? 0%, None of the above?

Is it true that there is no presumption for 2008 available, meaning that a 2007 val and a 2008 AFTAP must be completed by 4/1/08 to avoid the restrictions?

0% under current guidance. ASPPA COPA and others told the IRS it should be 100%, but the IRS needs to change their view.

Restrictions on lump sum after 4-1-08 apply to new plans, until the new valuation is done. But the restrictions are only for lump sums under 436(d) and not for 436(b), ©, or (e).

Thank you.

A participant notice is required if restrictions apply. Section 101(j). Doesn't make any sense.