My Three Sons

Is there a cite for this? What happens if the plan is opened up providing past service accruals for the frozen years?

HB, why does the plan being frozen prevent a YOP for 415? If the participant is credited with the hours during an accrual computation period needed to accrue a benefit they get the YOP. It doesn't say that you must accrue a benefit during the year, just need to satisfy the conditions to accrue a benefit. "A participant is credited with a year of participation (computed to fractional parts of a year) for each accrual computation period for which the participant is credited with at least the number of hours of service (or period of service if the elapsed time method is used for benefit accrual purposes) required under the terms of the plan in order to accrue a benefit for the accrual computation period, and the participant is included as a plan participant under the eligibility provisions of the plan for at least one day of the accrual computation period".

According to the initial thread, the 401 Plan is deferral only (no employer contribution). If so, doesn't that mean that for Rate Group purposes, these deferral contributions must be ignored? If the Cash Balance Plan is tested on a DB for AB% purposes (rate groups above mid-point), and there are employer contributions, doesn't the deferrals have to be included in this test?

Wouldn't that require eligibility to be based on a reasonable class?

Yes, PSP. Any reason the PSP QRP couldn't be terminated and a new QRP established to replace it?

DB plan terminated in 2018. The two participants received max lump sum, and the excess went into a QRP. The two original DB employees are no longer on payroll, so no 95% issue. There are now new employees including a new owner. Remaining unallocated assets are over 1 million. Can we set up a new DB qualified replacement plan using the remaining unallocated assets.

Does your opinion change if the employee was just hired, so he is a NHCE for the current year, but his salary is 400,000 and he will be a HCE next year.