Pension RC Posted December 17, 2013 Report Share Posted December 17, 2013 I am working on a plan that the sponsor would like to terminate within the next 1-2 years. It has a 7/1 plan year and has a 2 month look-back, so the 417(e) segment rates used for distributions through 6/30/2014 would be the May 2013 rates. The sponsor would like to file the PBGC 500 in February 2014, let the PBGC's 60-day review period pass, wait until June, when the May 2014 rates are published, and to decide then if they should quickly make payouts by 6/30/2014 or, the May 2014 rates are more favorable, try to delay the payout until 7/1/2014 or later. If, in June 2014, they see that the trend is for the rates to increase, they'd like to amend the look-back month to a 1 month look-back and try to delay the payouts until June 2015 (after the one-year grandfathering period) and make payouts based upon the June 2014 rates. Is there a problem with doing this? Specifically, can the plan amend the lock-back month after the PBGC 500 submission (and 5310 submission)? Any thought would be appreciated! Link to comment Share on other sites More sharing options...
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