Basically, I asked the question in the Topic Description.

Assuming your 1/1/07 valuation has been long since been signed, sealed and delivered to the plan administrator, and also assuming that the AFTAP can be determined from the data in the valuation, can the valuation be used as the AFTAP?

Of course, most 1/1/07 valuations would not have used the "AFTAP" terminology. However, some that took longer to do may have it. I guess I will split my question into 3 scenarios, and ask whether there is a difference if:

1. The valuation report has a number that is specifically identified as the AFTAP.

2. The valuation report does not specifically refer to the AFTAP, but contains a number that is the AFTAP, that is labeled specifically enough or is accompanied by sufficient decsription so that it can be inferred to be the AFTAP.

3. The valuation report does not contain the number which is the AFTAP, but has sufficient information in order to calculate the AFTAP. (e.g. assets and current liability)

I'm not sure I understand what you are asking. Are you asking whether the previously issued valuation can serve as the basis for the calculation of the AFTAP, or are you asking whether the previously issued valuation can be relied upon by the plan sponsor as the equivalent of a certification of what the AFTAP is?

Is there a reason you would prefer not to issue a simple one paragraph letter (well, two if you count the circular 230 crud) that certifies the 2007 AFTAP?

The latter.

Andy-- personally, no, I feel I would just as well put together a certification now (distinct from the val), send it out and leave no room for doubt that what I did was proper. But I know others who feel differently. Their reason is that a one-paragraph letter x many copies = a lot of time.

Where is the language that states or implies the 2007 AFTAP must be formally certified? I haven't seen anything and no one here has brought this up as necessary.

Nevermind, I found it.

None of the above, in my opinion. Not only must the report identify the AFTAP it must explicitly state that the actuary is certifying it for the relevant purpose.