Effen

I will give it to the Sox. Beckett was incredible and the high prices Sox hitters finally appeared. I'm still not sure why they held Lofton at third, but once the next hitter hit into the DP, I knew the Sox were going to blow it open, which they did. I guess I just became a Rockies fan.

deleted due to mis-understanding - I was wondering what he was referring too. Thanks for putting my straight Belgarath. Now, can you do anything about the issues in the Middle East?

2 to 1 Tribe. Why is Red Sox nation suddenly so quite?

PPA in general will result in far fewer EA's, we won't need harder exams to accomplish that. If we did make the exams more difficult, it would be for the greater good of society. We would be just helping the next generation of workers to find another profession. Did the buggy whip manufactures keep training people once Ford started creating cheap autos? No reason to churn out more EA's, when there won't be anything for them to do.

Yes on the SAR (2006 5500) No on the PBGC funding notice (assuming you mean the 2007 notice) 2008 - who knows, add it to the list of things we are waiting for

I'm not sure I understand your question. A multi-employer plan is a negotiated plan, generally for union members. If someone isn't paying dues, they probably aren't a member of the union and therefore the employer is probably not making contributions on their behalf and therefore they wouldn't be benefiting. If you are thinking about discrimination issues, collectively bargained plans are generally given an automatic pass on most pension related discrimination issues. In other words, if an employer employs 75 people, 50 of those are covered by a collective bargaining agreement that negotiates contributions into a multi-employer plan. The other 25 are not union members and are not represented by the union during negotiations. The employer doesn't have to provide any retirement benefits for the 25 non bargained employees. The counter is also true. If the employer wanted to give the non-bargained employees 5 times as much as the union employees, that would be ok as well. There may be labor related issues in some states and there could be prevailing wage issues on some jobs, but those are generally not ERISA issues. Do you have a situation where the non-union workers are covered by a multi-employer plan? Can you be more specific about your situation.

Are they still playing baseball? Our season generally only lasts until May or so around here. Glad to see someone in this country still cares. Go Tribe! Did I miss something or were you referring to ASPPPPPA's conference as an "EA conference"?

I thought that was when you dreamed a lot about a couple of tee pees ..... oh wait, that is when you are too tense

Your right, "before, you completed the form, printed it out, and mailed it to the client for payment.", now you just complete the form and hit a button. No letter to write, no forms to mail, nothing to upload. Just hit the button and the client has the form. I agree the first year involves a little hand holding, but once that is behind you we've found things run fairly smoothly. We are on yr-2 with the system and have only had a few hand-holding calls. Most went very smoothly. We just spend our 15 minutes typing it in, and we're done. Not all change is bad, if you give it a chance. Ultimately what ever works best for you is the right answer. I was just pointing out that I don't find MyPAA all that difficult or problematic.

Everett - Great link!

I think only DC plans are permitted to charge for this. If it is a DB plan, I don't think you can charge the participant.

I guess I'm just the strange one, but I really find the MyPaa system pretty easy to work with once you use it a little. Even my most difficult clients have been able to handle it. I guess I just don't see what all the teeth gnashing is about. I have big plans and small plans and they have all seemed to be able to get it done.

Lots of stuff from the IRS that says you can not change assumptions when you amend a Schedule B. If you search this board I'm sure you will find the necessary sites. That said, I have seen actuaries who amended Sch B's and changed assumptions and the IRS never said anything (yet), but it is a "no no".

I have a new client who was required to provide the 2006 PBGC Participant Notice, but whose previous service provider (insert large national firm here) neglected to tell them about the requirement. I spoke to the previous provider and they agreed that one should have been done. So, I have prepared the notice for the client and told them to issue it ASAP. My question relates to the 2007 PBGC filing. As you know there is a question asking about the previous year's participant notice requirement. There are only 3 possible answers to the question. 1) Was not required to be issued, 2) Was issued on time and in accordance with all other applicable requirements, or 3) An explanation is provided here. I plan on selecting Option 3 and providing an explanation, but I am wondering how the PBGC will react. I know there is a potential $1,100 per day fine, but I can't believe they would actually asses it. Has anyone ever selected Option 3? If so, how did the PBGC react?

I agree

Unless it was a drafting error, I would assume this was done in order to lower the required contribution. As the actuary, you are not required to use NRA as your assumed RA. If you have reasons for using something different, I think that is ok. So if he's willing to tell you that he isn't planning on retiring until 60 (possibly in writing), and he gives himself a suspension notice once he reaches age 59, I think you have accomplished the same thing without violating 411(d)(6). You can assume a RA of 60 for funding, even though he is really eligible at 59.

Since no one else has responded I will give this a shot, unless something was changed in PPA 06 (which is possible since I haven't fully digested the cash balance provisions), in a traditional db conversion 411(d)(6) requires you to protect the accrued benefit and all of its forms of payments, including 417(e) requirements. Therefore, you can't just convert it to a cash balance account and forget about it. This was the heart of the moratorium the IRS put on cash balance conversions and led to lots of problems. My suggestion would be to simply start the cash balance at $0. Value the plan as two pieces, one for the frozen traditional plan and one for the cash balance piece. Don’t try to combine the two or you are just begging for 411(d)(6) issues.

I guess that is my point... are we all in agreement that you can no longer use annual factors to determine the max 415 lump sum or do you think you can still use the annual factor if the normal form is an annual annuity?

These are all good questions that should be addressed to your Fund's legal counsel.

Andy, are you thinking that the new 415 Regs permit you to use an annual factor to determine the maximum lump sum if the normal form is an annual annuity or would you be comfortable using it if it was just one of the optional forms of payment? I guess I'm struggling with 1.415(b)-1(b) ..."no adjustment is made to the benefit to account for differences in the timing of payments during a year (for example, no adjustment is made on account of the annuity being payable in annual or monthly installments). B) Other benefit forms. WIth respect to a benefit payable in a form other than a straight life annuity, the annual benefit is determined as athe straight life annuity payable on the first day of each month that is actuarially equivalent to the benefit payable in such other form"

This may help http://benefitslink.com/boards/index.php?showtopic=36253 Be careful not to pay out any top 25 HCEs

I think it depends on what the freezing amendment said. If the benefit was restricted by the 415 limit and not the formula, the fact that the formula benefit was frozen doesn't necessarily mean the persons benefit doesn't go up when the 415 limit increases. The document needs to define the benefit. When you apply the benefit formula in the document after the accruals have been frozen, what do you get? I have seen some amemdments freeze the 415 benefit and some that didn't.

In general I agree with Andy, assuming you have been paid to prepare the actuarial valuation. If they never paid you for the valuation, I don't feel you are obligated to sign the Sch. B. If they paid for the valuation, the Sch. B is simply certifying to the government the work you already did. You need to check your procedures and see if paying annual fee includes the valuation & Schedule B. Many large national firms will charge the client extra to prepare the Sch. B if they are fired after they do the val. I have had some situations where the clients pays the "extra" freight, and others where they pay me to redo the val and sign the B. I suggest that you contact the ABCD. My experience with them has been very positive getting through this type of situation. What about the PBGC filing?

My vote is with Tom Geer. Disclose all revenue & offset your fee. TPA recordkeeping is full of shady situations, that is why Congress wants more transparency. I would want to know what your competitors are doing, but I wouldn't set my policies based on their bad practices.

I don't know about HIPPA, but FWIW, we have taken SSN's off everything that we send out.