I would like to get some thoughts on the following:
Assume a plan offers three JSAs: a 50% JSA, a 75% JSA, and a 100% JSA.
The plan designates the 50% JSA as the QJSA.
I assume that means the 75% would be the QOSA. 29 U.S.C. § 1055(d).
Now, I understand that the QJSA and the QOSA must be actuarial equivalent to the offered SLA. 29 U.S.C. § 1055(d).
What about the 100% JSA. Is that also subject to AE requirements?
Thanks for your thoughts and comments!