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  #41  
Old 05-08-2019, 07:10 PM
AllIDoisStudy AllIDoisStudy is offline
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Originally Posted by CuriousJoe View Post
If the question stated that the plan was TH in all years, then it's possible that both years should have been counted and the later date of participation was merely the result of some undefined eligibility requirement having been met.

If no such statement was made, couldn't it be argued either way?
I'm not 100% sure on this so someone please correct me if I'm wrong, but I think you only give TH service for years you're a participant in the plan, so they'd only get 1 year.
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  #42  
Old 05-08-2019, 09:18 PM
xenoshroud xenoshroud is offline
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Quote:
Originally Posted by AllIDoisStudy View Post
I'm not 100% sure on this so someone please correct me if I'm wrong, but I think you only give TH service for years you're a participant in the plan, so they'd only get 1 year.
agreed. I got this one wrong too, but after looking at the regs, it says you dont need to include service while the employee is not a participant.
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  #43  
Old 05-09-2019, 10:37 AM
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Quote:
Originally Posted by DonaldStewart View Post
Pretty confident it was within 3 years. I want to say 12/31/14 vs 12/31/16 or 1/1/14 vs 12/31/16 at most. Also pretty confident I got it wrong.
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Originally Posted by CuriousJoe View Post
Regarding the True/False question about whether or not to treat a previously withdrawn employer as part of a subsequent mass withdrawal, it is stated on the PBGC website that "employers who withdrew during the three years prior to the mass withdrawal are presumed to be part of the arrangement or agreement and are treated as if they had withdrawn in a mass withdrawal".

Does anyone remember the dates included in the problem? I was stuck on this one, and ultimately answered False simply because the employer was said to have withdrawn completely (just a shot in the dark on my part).
CuriousJoe, you are correct that is what the PBGC website says. I didn't take this exam (passed it previously and work with ME plans) so this may not have had a bearing on the given question, but I have always taken issue with the (in my opinion) poor wording of that on the PBGC website:

Quote:
Originally Posted by PBGC website:
Mass withdrawal of all or substantially all employers

(ERISA Secs. 4041A, 4219 and 4281)

If all of the contributing employers withdraw, the plan is terminated in a mass withdrawal. If substantially all of the employers withdraw, there is a non-termination mass withdrawal.

Liability for employers withdrawing within the plan year in which a mass withdrawal occurs will be calculated under the normal rules, except none of the relief provisions discussed below (such as the de minimis reduction or the 20-year cap) would apply. Also, certain benefit reductions and suspensions apply.

In addition, employers who withdrew during the three years prior to the mass withdrawal are presumed to be part of the arrangement or agreement and are treated as if they had withdrawn in a mass withdrawal. PBGC has issued regulations describing the various administrative steps the plan must take if a mass withdrawal occurs.
I bolded the poorly worded part above. The way it is worded leads one to believe that you declare a mass withdrawal on a given date and you go back three full years from that date.

The plan trustees must declare that the plan is terminating due to a mass withdrawal. Whenever that happens, then anyone who withdrew in that plan year AND the two prior plan years are part of what can essentially be a period that is up to 3 full years. The period definitely covers 3 different plan years, but is really only a 3 full year period if the declaration that a mass withdrawal occurs is made at the end of a plan year. It is in the best interest of the plan to not declare a mass withdrawal at the beginning of a plan year, since in that situation it would have been best to do it a few days earlier at the end of the prior plan year so they could reach back and rope in employers who withdrew another 11.99 months earlier.

If you want to look this up in the law and regs, here are the citations:

ERISA section 4219(c)(1)(D): This is where the reference is to 3 consecutive plan years for the employers who withdrew. My read is that this is the current plan year (when mass withdrawal is declared) plus the two prior plan years. Sometimes 3 full years for a mass withdrawal that is declared at the end of the plan year, but sometimes not.

PBGC Regulations starting with 4219.11 and 4219.12 give the details that for these previously withdrawn employers, you can now allocate them additional withdrawal liability if their calculation was previously limited by the 20-year payment cap, de minimis amounts, etc.

If the PBGC updated the wording to say the following, it would be correct in my view: "employers who withdrew during the three years prior to the mass withdrawal valuation date" where mass withdrawal valuation date is defined in 4219.2 as the last day of the plan year in which the plan terminates by mass withdrawal. Definitely a fine point in the end, but the JBEA makes a living over changing an answer from right to wrong based on language being more technical than it should be under exam conditions.
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  #44  
Old 05-09-2019, 05:01 PM
ihatememes ihatememes is offline
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Any chance we could refresh the analysis file? We received ~20 responses since it was posted - and it probably won't be updating much anymore.
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  #45  
Old 05-09-2019, 08:01 PM
blueconno blueconno is offline
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Here's the updated analysis spreadsheet, which now has ~70 entries.
Attached Files
File Type: xlsx EA2L PAK 2019.xlsx (32.5 KB, 228 views)
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  #46  
Old 05-29-2019, 04:15 PM
mwells1695 mwells1695 is offline
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Just emailed the Joint Board and got a very prompt response:

"We expect to post the exam by the end of this week."
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  #47  
Old 05-29-2019, 04:51 PM
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That would be much faster than the last two years!
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  #48  
Old 05-30-2019, 04:35 PM
peteyb313 peteyb313 is offline
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Exam is posted.
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  #49  
Old 05-30-2019, 05:32 PM
lrbenson81 lrbenson81 is offline
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72.

And now my watch begins.
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  #50  
Old 05-31-2019, 09:37 AM
CuriousJoe CuriousJoe is offline
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A few points/questions after reviewing the exam:

1. I can't help but think that the first question was devilishly tricky. I assumed the small plan waiver applied. I didn't realize that particular waiver was not applicable in the case of a payment due 8 and 1/2 months after the end of the plan year. (Seriously, I have to hand it to the Joint Board. They managed to test perhaps the one part of Form 10 that I didn't commit to memory.)

2. Question 24. Were continued accruals meant to be provided to Smith? I don't see how else the answer could be C. I think I answered the question assuming an actuarial increase was provided to both members. Of course, doing so results in a final answer of approximately $1263.75, which I remember thinking was a little strange, given the ranges provided.

3. Question 42. How are they getting B? Were we meant to limit the top heavy average salary to 4 years, and if so why? Does it have something to do with the plan effective date? After reviewing the question, I would assume (as I'm sure I did during the exam) that the default five-year top-heavy testing period applies regardless, resulting in what I believe to be a required increase of $252. I feel like I'm missing something small, but for the life of me I can't figure out what it is.
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