Notice 2014-53, the recent guidance from the IRS on pension funding stabilization under the Highway and Transportation Funding Act of 2014 (HATFA), contains a provision that is in accordance with a request by ASPPA’s College of Pension Actuaries.
On Aug. 13, the ASPPA and ACOPA sent a comment letter requesting that filing a 2013 Schedule SB using MAP-21 segment rates will be deemed to be an election to defer use of the HATFA rates until 2014. That is the position the IRS took in the notice. ASPPA and ACOPA recommended that if the schedule SB for a plan year beginning in 2013 is filed no later than 30 days after guidance is issued, no supplemental or amended filing should be required. They further suggested that for plans that have filed, or will file, the schedule SB but choose to apply HTFA rates to 2013, the results of applying the HTFA rates simply should be reflected in the opening balance of the 2014 schedule SB. They noted that having to amend the schedule SB would require filing an amended Form 5500, and would not only put an additional financial burden on the plan sponsor, but would place additional, unnecessary processing demands on the agencies.
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