Calendar year PBGC covered plan with a plan termination date of 12/31/07. The termination was submitted to the PBGC and IRS. The plan assets have not yet been distributed. Is a DOL funding notice required for 2008, and if so what do I do about the FTAP since there was no 2008 actuarial valuation required?

Suggest you contact Amy Viener at PBGC on this one. I found her helpful and she responds promptly. I believe she was formerly with Wm. Mercer.

Viener.Amy@pbgc.gov

Thanks.

David?

If you get an answer, would you post please? Thanks.

That's me. I emailed Amy at the PBGC yesterday. I will let you know if I get an answer.

It's not looking good.

Related question from a colleague:


PBGC covered calendar year DB plan term date 03/31/08. All assets distributed May 2009.


Is a 2008 AFN required?


Is a 2009 AFN required?



I think yes to both. Agree? David, anything else you can add to this from your discussion?

In my opinion (shared by TAG), plans that terminated before 2008 are not subject to PPA requirements such as the Annual Funding Notice.

Instead, I think that plan is supposed to distribute Summary Annual Reports.

...... Jeff

AndyH, I did not see your post until today. I never got an answer on that question. Nobody called me back. It's a long story but luckily I was not the person that had to make the decision for the sponsor so I let it go.

Reagrding your question, I think it's clear that for 2008 the AFN is required. For 2009 it sounds like everyone was paid out prior to the time the AFN would be due so you don't have any plan participants to give it to.