JAY21
Dec 22 2004, 04:22 PM
Can anyone confirm that under 401(a)(9) that even rollover assets from outside plans (say a DC plan) rolled into a DB plan must still be paid out under the DB annuity method instead of the account balance method (I'm aware of the 2 year transition rule on reliance on prior proposed regs but I'm ignoring that for the moment). Thx.
AndyH
Dec 23 2004, 11:03 AM
A rollover account must be separately maintained, so I would consider it an individual account subject to the rules govening individual accounts. I have not researched it, it is just a reaction. I would not even bother to research it; it just seems like common sense. These rules are so convoluted anyways regarding the account balance method which never existed for DB plans. Talk about massive noncompliance.
mbozek
Dec 23 2004, 03:45 PM
Rollovers to a db are not part of the annual benefit. reg. 1-415-3(b).
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