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How do I coordinate the 415 limitation when computing the lump sum payout for ee in 2 pension plans? total accrued benefits < 415 limits


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EE covered in a frozen pension plan and another pension plan of same employer. The sum of the monthly accrued benefits in both plans do not exceed 415 benefit limits. The lump sum is the greater of benefit based on plan rates ( '94gar 5%) or 417e rates but not to exceed applicable 415 limits. In this case 417e applies and the question is how to compute the 415 maximum lump sum. The plan doc in plan A and plan B states only  that if the sum of the accrued benefits from all plans exceed the applicable 415 limit, the limitation is first applied to plan A.  It doesn't cover this situation since the aggregate limit is not exceeded.

John has a monthly accrued benefit of $10000 in plan A ( frozen plan) and 1350 in plan B. The applicable 415 limit is $14166 per month at age 65. Not clear on how to compute the 415 lump sum for each benefit. 

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Is the participant actually requesting a distribution or is this just for valuation purposes?

If this is just for your assumptions I think you can do anything reasonable. For example assume that A is distributed first and then limit the lump sum in B to the maximum lump sum minus the lump sum value of A.

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This is for an actual distribution! I was thinking that since the 417e LS would exceed the 415 limits, I could use the method in the Plan for the situation in which the sum of the 2 DB benefits benefits would exceed 415 and then apply to the limit first to Plan A. But uncomfortable with this. I was hoping some others might have faced this issue before with their own clients, or who had plan provisions that would cover this.

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