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Is an amendment to a DB Plan to raise QPSA from 50% to 100% permissible?


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As far as I know, there is no prohibition to being more generous than the statutory minimum.  However, I see a couple of considerations:

-  Could this proposed amendment be considered discriminatory?

-  Would the sponsor want to improve the QPSA for all potential deaths?  ie, distinguish between the death of an active participant vs. a VT participant?

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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Thanks you David for responding to my question. I don't anticipate the amendment would be discriminatory since it is coming from a well funded multi-employer plan that is making the change for all current and future participants (and its not aimed  or created based on the medical condition of a particular individual). 

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