Yes, we are still doing end of the year valuations for all of our plans under 100...

I have several questions:

Am I correct in the following assumptions?

1) All plans regardless of size are required to have quarterly contributions for the plan year following a plan year with a shortfall.
2) For an end of the year plan with prior year shortfall, even though, the 2008 required contribution has not been calculated until after 12/31/2008, contributions were still needed to be made on 4/15/2008, 7/15/2008, 10/15/2008 and 1/15/2008. These missed payments are then penaltized.

follow up questions.

1) Do pbgc covered plans have to notify the pbgc of missed quarterlies with form 10?
2) Is the 5% penalty applied the same way as for beginning of the year plans?

Thank you,
Andrew

1) Yes
2) Yes

follow-up
1) Yes, but on the COPA board it was speculated that the PBGC might waive the requirement, but nothing yet
2) No one really knows. At this point, just do something reasonable.

follow-up

1) form 10 is due 30 days after the quarterly contribution is required, so if we don't hear anything soon, we should file them soon for 4/15 quarterlies. Correct?

That is the way I read it.

Kind of interesting that if you might need to file a Form 10 before you really know what your required quarterly is for an EOY val. Lets say the market takes off so much that the 2009 required is $0. If that is true, you didn't really have any quarterlies due and therefore the Form 10s you filed weren't necessary.

That's the exact reason I was thinking this whole thing with eoy plans is crazy.

Thank you very much for you help.