Internal Revenue Code (Code) section 436 as added by the Pension Protection Act of 2006 sets limits on benefit payments and pension accruals for defined benefit plans that are "underfunded." As discussed in the December 2011 EB Update, the IRS issued Notice 2011-96 extending both the deadline to amend a plan to satisfy Code section 436 and the period during which such an amendment is eligible for relief from the anti-cutback requirements of Code section 411(d)(6). The IRS has not issued an additional extension on the amendment deadline. Accordingly, calendar-year plans subject to Code section 436 should ensure that their plan amendments have been adopted by December 31, 2012.