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Plan Integration - 401(l)


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A plan has a formula of .9% below CC and 1.4% above CC. Seems fine at normal retirement. However at age 55, based on the ERF factors the disparity is .32, but the maximum is .316 for someone w/ SSNRA of 67. Does this mean that this plan does not pass 401(l) and does not meet a nondiscriminatory safe harbor plan formula?

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I think that depends on which table you are using. In 1.401(l)-3(e)(3) are four tables: Tables I, II, and III are for SSRA of 67, 66, and 65. However, Table IV is a simplified table that can be used in place of the other three when the plan uses a single disparity factor. Read this section of the regs. carefully, and check the document.

[This message has been edited by pax (edited 03-07-2000).]

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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