ubermax

I agree with SoCal, with diminishing DB business why would a Datair, for example, spend additional money to develop something like this ? but instead of a val sys download with a licensing fee and passwords you could do the same through a website - but to answer your question I don't know of anyone that's offering it . maybe call Datair and pick their brain .

I think having a lot of different forums is a good thing & as Effen pointed out they each tend to draw different professional types - and I'm not faulting ASPPA , they needed to change something since the "in-house" forum wasn't seeing a lot of traffic - Linkedin is certainly a better venue than either FB or Twitter

I know that, before the association with Linkedin, the ASPPA practitioner forums didn't draw much activity ; and I'm also aware that communicating via social media is a "now" thing and we sometimes have to break out of old grooved tracks and embrace the new ; but I also think that in some situations "old way" is better than "new way" ; I've been going back and forth between Blink ,Actuarial Outpost, ACOPA, and ASPPA's Linkedin group and I have to say that I like the visual presentation of the others better than Linkedin. For this benefits professional/practitioner seeing a great many questions and topics together on the screen is preferable to seeing someone's picture with a question and only seeing a few questions per screen ; the search features of the other forums are also better and obviously designed for topic research. And yes I do have a FB account and now also a Linkedin account because I like ASPPA - but I don't think a social media approach is an efficient one in this case. Would be interested to know what others think ?

yes, I agree but I'm now second guessing my prior thread, i.e. if the DB combined limit is 28% of pay and 404(o) is 27% what's to prevent a 28% deduction ? is there guidance that says the individual limit trumps a combined limit ?

if I just look at 404(a)(7)(A) , total deductible not > max(25%, MRC) and then the last paragraph of 404(a)(7)(A) says that the amount necessary to satisfy the minimum funding standard of 412 shall not be < (FT-Assets) . so if MRC is 30% of pay & (FT-Assets) is 32% of pay and the DC contribution is 10% of pay wouldn't the deductible limit for the DB be 28% of pay, i.e. (32-(10-6)) as long as the 28% is < 404(o) as applied to the DB plan ? My beginning point is interpreting the words in 404(a)(7)(A) - where am I going wrong ?

thanks for the reply Effen - so for DC contributions > 6% , since non-PBGC plans would include the sole props & partnerships that are common in the small plan market, I guess the 25% of pay would most likely be greater than the max ( MFA, ( FT-Assets) ) and hence the 31% in practice - is that the thinking ? but do you agree that generally it's max ( 25% , max(MFA,(FT-Assets) ) ?

I'm revisiting 404(a)(7) and the deduction limitation where DB & DC plans are involved - 404(a)(7)©(iv) tells me that PBGC covered plans aren't addressed by 404(a)(7) , i.e. I guess only the individual limits are applicable - for the plans that do fall under (a)(7) , it looks like : the combined plan limitation = max ( 25% of comp, max( MFA, FT-Assets)) , where MRC = Min.Req.Contribution , FT= Funding Target. If the only DC contributions are deferrals, then the individual limitations apply , e.g. 404(a)(3) and 404(o) . If DC contributions are <= 6% of comp , then again the individual limitations apply. If DC contributions > 6% of comp then, only counting the amount of DC contributions > 6% , the combined plan limitation expressed above is used. I realize that WRERA is ancient history but would appreciate knowing if the above interpretation is on track and, if not , hopefully someone will provide some insight. thanks in advance .

what would happen if my wife retires in 6 months - sales charge or no on the withdrawn assets ?

Who is the provider for the plan that is being acquired? Is it an insurance company? yes an insurance company ; and I'm using provider & administor/recordkeeper synonomously (sp?)

my wife's visiting nurse agency has been acquired by another - she's been told that, instead of her 403(b) account being moved to the plan of the acquiring agency , it will remain with her current provider - only new monies will go into the plan of the acquiring agency. question : how typical is this situation , i.e. common , very rare, etc. ?? and also what would be a possible rationale for keeping the account balance with her currrent provider rather than moving it to the new plan ? I'm asking these questions because she's not getting help from her HR department.

talked to JB a week ago - said they're still processing a lot of apps - suggested calling back in couple of weeks - as someone else said if you've satisfied the criteria then you can sign using 11 prefix - but I agree ,as with you I'd like to have the paper - hang in there !!!

thanks Zimbo !!

Does anyone have a link to the 3 col. version of the new 430/436 regs. ?? - I call it the actual Fed. Reg. version and it's easier to read and less pages than the one in the recent ACOPA newsflash .

The description of asset smoothing in the proposed 430 regs seems to mimic Approval 11 of Rev.Proc. 2000-40 (i.e. average value without phase-in). H.R. 7327 (WRERA) seems to amend the proposed reg by introducing expected earnings into the mix using a rate no greater than the applicable segment 3 rate. Algebraically do we end up with one of the smoothing methods in 2000-40 or is it new and to be described in forthcoming guidance ?

I have a DB plan that failed the general test for 2007 - it's annual testing and the non-highs will get a bigger accrual for 2007 - does the 2007 funding valuation also need to be re-done ?

In my case the late quarterly penalty rate for 2006 is 7.9% and my funding or valuation rate is 8% and so there wouldn't be any penalty interest for the late payment. My question is more one of timing - the Credit Balance at the end of 2005 is $0 without recharacterizing 2006 payments as 2005 - quarterly payments of $X for 2006 are made on 4/13 and 7/21 - if both are used for 2005 then the Credit Balance is 2X on 12/31/2005 and the 1/1/2006 FCLP is 90% - a good thing for this client !!! The question in my mind becomes : Is the 2nd quarterly payment obligation satisfied given that the Credit Balance to cover it isn't effectively created until 6 days after the due date ?

A few questions : (1) what does averaging market values over at most 2 years mean ? Is it the averaging methodology described in the 412 regs ? and (2) If you change to say market value for a 1/1/06 valuation, are you locked in until 1/1/2011 or do you have to conform to 2 years in 2008 & stay with it ? And I'm assuming the 2 year averaging methodology isn't required until 2008 ?

I have an hourly plan and a salaried plan with the same sponsor - each had under 500 lives reported on the 2005 PBGC Form 1 - but in total there were over 500. Do these plans need to file a PBGC Form 1-ES ?

Thanks all !!! and yes , Blinky litespeed=LIBOR -----home & work pseudos ---- I do a lot of road biking and I ride a Litespeed , made in Tennesee -- very light ---and the London Interbank Rate ( LIBOR) sounded good at the time !!!

Thanks Pax and Blinky !! In my example I mentioned that Coverage was satisfied by aggregating plans and using the Ratio Percentage Test - and this seems OK from looking at the 410(b) regs - but it almost seems like that's too easy - the Profit Sharing plan could be a very minimal plan. It almost seems like the Average Benefits Test would be required ??

Want to General Test a window that provides 3 years added to age and service for those eligible for the window and not receiving Minimum Distributions but only a flat $10,000 for a couple of non-highs who are eligible for the window and receiving Minimum Distributions. Have a couple of questions : (1) Are the accrual rates and corresponding rate groups to be tested created by looking at the entire plan's participants or just those eligible for the window ? (2) If testing on a benefits basis would you simply convert the $10,000 amounts to an annuity at current age - both participants are older than the testing age of 65- and then for say the annual method would the change in accrued benefit simply be the converted benefit plus the otherwise accrued minus the beginning of year accrued ? For those eligibles not getting the $10,000 and again using the annual method I'm assuming the accrual rates would be determined by taking the accrued benefit reflective of the 3/3 and subtracting the beginning of period accrued which naturally doesn't reflect any enhancement ?

It's unit benefit and does pass 410(b) - it just seems too easy ! - but in this particular window offering it makes sense to have coverage be a more difficult hurdle. thanks again SoCal Actuary !!!!!!!!!