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Old 12-03-2018, 04:20 PM
CrispyCobb CrispyCobb is offline
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Default MRC for merged plans

I have a question about how to determine the MRC for the ongoing plan when a merge of 2 plans occurs in the middle of the ongoing plan's plan year.

There were initially 2 plans:
  • a 1/1 - 12/31 plan that is overfunded and has had $0 MRCs for the past several years
  • a 9/1 - 8/31 plan that is underfunded and has some outstanding shortfall bases

A 9/1/2017 amendment merged the 9/1 plan into the 1/1 plan effective 9/1/2017.

Would you:
  1. value the merged assets/liabilities as of 1/1/2017 to determine the 1/1/2017 MRC for the ongoing plan (I suppose this would require a 412(d)(2) election),
  2. calculate the 9/1/2017 MRC for the merging plan, prorate it for the 4/12 months remaining in the 2017 calendar year (basically treat it like a short plan year from 9/1/2017-12/31/2017), and add it to the 1/1/2017 MRC for the receiving plan, or
  3. something else?

I searched, and I don't see any guidance on the 430 requirements for merged plans in the year of the merge, but maybe I missed something.

Thanks in advance for any input!

Last edited by CrispyCobb; 12-03-2018 at 04:25 PM..
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