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Floor Offset plan-uniformity

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Our firm took over a floor offset DB plan a couple of months ago.  The plan's formula provides 4.75% per YOS to the business owner, and 0.5% to each other participant.  The benefit offset from the PS plan is limited to 0.5% of pay.  The participants except the business owner receive a 6% contribution in the PS plan.  The prior actuary was treating this as a uniform allocation, I assume because the participant account offset is limited to 0.5% of pay for all participants.  Essentially, the PS account was bifurcated into the portion which provides 0.5% of pay, and the remaining portion.  Does this fly for the uniformity requirement for 401a26?

A further question, does anybody know what requirements must be met to use a preapproved plan document for the PPA restatement for a floor offset plan?  My document seems to allow this, but doesn't elaborate on what requirements the plan must meet to use.   

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I (and many if not almost all from the ACOPA board) think that lack of a ps contribution to the owner blows the uniformity rule.   Not sure about the limited offset part without further thought.

I can't help with your document question.

 

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