I have been talking with clients regarding the new notice which is due the end of April. The new funding notice asks for carryover balance / prefunding balance. These numbers depend on the whether the plan is a BOY or EOY valuation in my opinion.

Is the following interpretation correct:

An EOY valuation has to take the beginning of the year balance and increase by the effective rate to get the EOY balance used to offset the assets. Similarly, the credit balance is adjusted to valuation date for the current liability percentage.

Similarly, the current liability at the EOY is the old 1(d)(2)(a) + 1(d)(2)(b) (from the old Schedule B) for years prior to 2008. The funding target is used by itself for the 2008 liabilities. This appears to be inconsistent (or maybe just the liability is used from the old Schedule B)??

Thanks for any and all comments.

The form due by April 30 is for medium and large plans. Small plans have the notice due with the 5500 filing.
The April deadline applies to plans that were required to perform a beginning of year valuation as of 1-1-2008.
The information from the old Schedule B appears to apply only for determining a prior AFTAP value. For the filing year, the new value is drawn from the 1-1-08 valuation.

Now the challenge is to determine an estimated end of year value for those 1-1-08 valuations.
Since you are stuck with a different interest rate, it looks like you need another valuation. See the extensive discussion in the ACOPA forum as well.

Nut Question: If your headcount is over 100 and your liabilities are less than 50,000,000, what is the penalty for not distributing and filing the Notice until you file your 5500?