david rigby

The ability to do basic research is an important skill. You could ask that someone to "prove it".

Effen was/is correct. The bill was signed today.

What do you want the answer to be? Amend NRA?

Data as of 29-JUN-12 (Friday) Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 3.66 3.66 Aa 3.81 3.75 3.78 A 4.13 4.19 4.16 Baa 4.99 5.13 5.06 Avg 4.31 4.18 4.25 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 0.53 Medium-Term (5-10 yrs) 1.12 Long-Term (10+ yrs) 2.28

Trying to avoid any comments on the poor economic theory behind this legislation , and assuming it becomes law, does anyone have any reasonable estimate of how long it will take the IRS to give us this 25-year average?

Be careful to avoid a plan design that excludes the younger HCE permanently.

PS is usually discretionary. You don't need to freeze the plan to stop a discretionary contribution. Are you sure the original post has used correct terminology?

Instructions for Line 9f say to use the periodic benefit. Just my opinion, but I view this form as providing a Yes/No answer to the question, "does the participant have a benefit udner the plan?" The precise dollar amount is less important.

It appears there are two plans: ESOP and "annuity". Get information on each.

1. www.fasb.org 2. Hover your cursor over Standards - Click on Pre-codification Standards for the "old stuff", or - click on Accounting Standards Codification for the "new stuff". 3. Click on Login 4. Select either Basic View ($0) or Professional View ($850).

99.99% of all plan sponsors access their MyPAA account no more than 2 times per year. All of them will be faced with an expired password. Brilliant design.

No debate about the "obvious" answer. Just wondering if the bureaucracy / regs might look at it differently.

I got this question twice recently. Maybe my easy answer should be re-thought. With Ford and GM amending their plans to offer a lump sum to current retirees, I wonder about the case of a retiree who choose a J&S, but the spouse is now deceased. If you bought a commercial annuity for this retiree, the price would (I assume) value this as a LA to one person. Suppose the plan pays a LS (417e3) to this retiree, would such LS be based on the remaining LA? Any interpretation that might require the plan to value it as a LS of a J&S benefit?

Yes. However, the plan may not say, in which case the presumption (at least by me) is annual compounding. Caveat: Check for precedent, especially with respect to how to handle a fraction of a year.

Is this a cash balance (or other) hybrid plan? - If so, showing a balance probably makes sense (but it won't be frozen). - If not, take the PVAB off the statements. Never use the word "account", always emphasize the annuity form of the accrued benefit.

What a mess. I agree with SoCal, but caution you to look for other docuemtnatino (precedent, administrative interpretation) that might help decide whether "portion" has any reasonable limitations on its definition.

BTW, I not aware of any requirement that the plan definition of AE must include both interest and mortality. For example, the plan could define the AE for post-NRA as "8% per year".

Some might use the word "earning", but not I. That word implies an investment account, and an accrued benefit is not an account. Instead, I describe the actuarial increase as adjusting the payment to reflect the payments not received between NRD and actual retirement, or some such nonsense.

Don't get too excited. It's not going to happen.

http://www.irs.gov/pub/irs-pdf/i1099r_11.pdf Is the explanation under "Box 8" on page 12 relevant?

Why restrict this to small cashouts?

No. No.

Two years later, any new developments? Inquiring minds want to know.

Might be prudent to ask what new information has changed his mind?

My best guess; please check the 5500 instructions: - the "old" plan exists until all assets have been transferred to "surviving" plan. Note: this does not require physical movement of assets, but does require changing title of which plan owns those assets. - a merger date creates the end of the plan year (if not already EOY); - the 5500 includes a checkbox for "final filing"; if this has been properly checked, no filing the next year.