Calavera

Here are my $0.02. I would agree with the attorney and disagree with your boss: 1. Process of a DRO qualification doesn't require a comparison between A DRO and a divorce decree. 2. You only need to determine if a DRO could be administered as written (along with other qualifications such as names, addresses, etc.). 3. Second paragraph of Item 6 is needed for a DRO, so it can be administered. Just imagine a case when the total account is less than the amount specified in a DRO. You will never be able to administer it. If you are certain that the total account is higher than the amount written in a DRO, then second paragraph has no impact. 4. If the participant insists on a "non a penny less", the divorce decree will need to be amended to instruct what to do if the total account balance is less than the amount specified. However, you cannot pay more than is in the account, so the second paragraph of Item 6 is still needed.

Sometimes searching on LinkedIn may help. Also, this one was helpful for me https://www.fastpeoplesearch.com/

You will be signing the 2025 SB, so you will need to put the correct AFTAP on your SB, which would be different from the prior actuary's certified AFTAP. The calculation of the AFTAP for EOY valuations is different. I assume your AFTAP will still be over 100%. In this case, I don't think you actually need to issue the re-certified AFTAP, but I would suggest doing it anyway to have clear records.

No, you cannot transfer these benefits to an IRA. Sending them to PBGC probably will be cheaper than going through an annuity purchase process.

Not really answer to your questions but alternatively, he can take full benefits as a lump sum, take RMD amount (not allowable for a rollover) based on the account method, and roll over the rest to an IRA.

Yes, BCD would be established from then. I would provide all applicable forms of benefits as of that BCD, including lump sum that would be payable at that time. Then, based on the election, I would figure out what should be paid now, including missing payments and interest. And don't forget about RMD issues as well.

In addition, a BCD should be the first of the month in which your AE increases cross the 100% pay limit. So, the final benefits will be slightly below the 100% pay limit.

Moreover, with unfreeze you can change the benefit formula to target precisely what your client wants to accomplish.

Under 2nd, I meant to remove procedural QRP setup and just give this back to participant upon plan termination. For one person plan you just need to be sure that the total payout is under the 415 limit.

2nd is much easier to implement

With the range certification by 9/30, the actual AFTAP needs to be certified by 12/31. Don't even need to certify 100% or higher, the range certification of 80% or higher should be sufficient.

For the EOY val you need to use actual net earnings, so if benefits are defined as a percentage of current compensation, someone would need to correct it. Just some suggestions: 1. Confirm how benefits are defined and go from there. For a DB plan it may be a percentage of an average compensation. For a CB plan it may be an amount specified in the plan document without referring to any compensation. 2. Ask prior actuary if it was assumed that both companies adopted the plan or ask him to justify compensations used for calculations. 3. See if you can get copies of all Schedule SBs and copies of tax forms to compare earnings and deductions. Or just tell this prospect to find another TPA, since you are not interested in this case

See if you can change any assumptions to at least reduce the 2024 minimum required contribution.

Is it beginning of the year valuation?

Just a reminder that 110% is calculated after the payment and the target liability could be used for the ratio. So, when majority of benefits belong to the retiree, it's usually not too hard to overfund the remaining target liability by 10%.