I just got the email from ASPPA with the conference brochure. This meeting will be in Atlanta, GA on January 15-16, 2009:
http://www.asppa.org/archive/conf/2009/2009bcos.htm
Looks like I’ll be on the podium with Jim Holland to talk about “PPA 06 Funding Issues”. Darn, instead of 2 days to cover the topic, we only have 1 hour and 15 minutes!
A few students have pointed out that some of my practice problems are not 100% clear. Well, yeah, DUH – this is PPA 2006 we’re talking about, right?!
The issue has to do with IRC 430 and single employer plans. When determining the exemption from establishing a shortfall amortization base, a plan may be able to use an applicable percentage that is less than 100%.
IRC 430(c)(5) has several criteria the plan must meet. One of them is that the plan was not subject to the 412(l) Deficit Reduction Contribution in 2007. In some of my practice problems, I make this statement: “The 412(l) Deficit Reduction Contribution for 2007 is zero”. But that is not necessarily the same as saying that “the plan was not subject to the 412(l) Deficit Reduction Contribution in 2007”.
It is definitely possible for a plan to be subject to 412(l) in 2007, and yet the value of the DRC is zero. You are supposed to interpret the statement in the problem about a zero DRC to also imply that the plan was not subject to 412(l).
Based on my review of the 2007 exam, they avoided any potentially unclear language on the exam problems. Next year, I will clarify the language in my practice problems.
PRACTICAL NOTE
There is additional detail in the proposed regualtion on this idea. It states that the transition rule “does not apply to a plan … that was subject to 412(l) for the pre-effective year ….” The regulation makes it clear that a plan can be subject to 412(l), and also have a zero DRC.
The proposed regulations are not on the EA-2A syllabus. In 2008, the EA-2A exam questions have to be based solely on the Internal Revenue Code. You should not worry about details in the proposed regulation.
I have gotten emails from several students asking about the 414(l) / 415 / 416 questions on prior EA-2B exams.
There is no need to look at any old 414(l) questions. Most of the problems test stuff that was on the EA-2B syllabus, but that material is NOT on the EA-2A syllabus.
For 415 questions, ALL of the EA-2B questions are based on the old 415 regulation – so don’t bother looking at those. I will be revising / creating new 415 practice problems.
You can look at the EA-2B problems on 416 for years 2002-2007. Prior to 2002, the 416 problems were based on old rules that were changed by EGTRRA in 2001.
Several students have asked me about possible differences between the 2007 and 2008 exam. I don’t really anticipate any significant difference in content of the exam, or the difficulty level. The 2008 exam would be much harder if the proposed regulations were on the syllabus – but that has never happened.
Just be sure you pass this exam before 2010. That will be the first year that
1. The final regulations will be on the syllabus, and
2. The question writers will have enough time to study the regulations to start getting into the finer details
I’ll be mailing out CDs on 07/30/08 to the students who signed up for the online seminar. I am finalizing printing of materials for everyone else. I will start shipping those out on 07/31/08.
You’ll need to buy a BIG binder. This year clocks in at 2004 pages!!
Several students have sent messages asking if the online seminar has the right overheads. The short answer is Yes.
The long answer is that 99% of the overheads have not changed since last year. I have re-recorded several pages, but the presentations have not been re-constructed yet.
I had hoped to upload more presentations to the web site this week. But Murphy’s law got me. Now I fly to Seattle for a few days.
I’ve just recovered from a hard disk failure that occurred on Thursday. The timing was “perfect”, since I had made way too many changes to the files on PPA 2006. The software I used to recover the data partitions screwed up everything else, so I couldn’t restore my June 10 backups.
“Rick G” is Rick Groszkiewicz. It is pronounced grosh-kev-yitch. This is a Polish name, which is why my company name is Software Polish.
I have been teaching the enrollment exam seminars since 1983(!) I am a Fellow of the Society of Actuaries, an Enrolled Actuary, a member of the American Society of Pension Actuaries, and a member of the College of Pension Actuaries.
I’ve worked in software development since 1983, on defined benefit pension plans. Current software development is done primarily with Visual Basic version 6.0. I do very small consulting projects for actuarial firms.
My main business activity is teaching the EA seminars. I teach EA-1 and EA-2B seminars in the spring. I will do an online seminar for EA-2B in 2008.