SCooper

Hi all, Wanted to start a discussion on what future interest crediting rates would be considered reasonable assumptions for funding valuations for Market Based Cash Balance Plans. These plans are designed to reduce risks of underfunding but if the assets are aggressively invested and, depending on the method of determining a future return assumption, the assumed future interest crediting rate could be higher than the relief funding rates resulting in minimum required contributions greater than the pay credits. Is anyone aware of any regs or approved methods for determining a reasonable future interest crediting rate that would not result in unreasonable underfunding results and minimums greater than actual pay credits? It seems applying a 6% cap on the projected ICR would be reasonable considering the new legislation in Secure 2.0 but this is still high. Curious if anyone ties the projected ICR to a segment rate similar to how the future ICR would be determined at plan termination for market based rates? Goal is to avoid underfunding results when the plan sponsor is funding the annual pay credits and the plan has a more aggressive asset mix.

We have a cash balance plan that set a termination date in September this year. We permissively aggregate the DB and DC plan each year to pass general testing. Does the plan termination date create a short plan year for the DB plan and does that now make the two plans unable to be aggregated due to differing plan years or is amending the plan to terminate 9/30/2023 not creating a short plan year for testing purposes? No assets will be distributed this year and both plans define the limitation year as the plan year. I don’t believe the regs are concrete on this scenario and that it could be interpreted as being a short plan year. But it could also be interpreted as being a short plan year only during the year when the assets are distributed not necessarily when the plan term date is effective. Secondly If the DC plan is terminated 9/30 as well, I’m thinking it would be reasonable to aggregate them under this scenario? Thank you!