david rigby

Here is a similar discussion (1999): http://benefitslink.com/boards/index.php?showtopic=5414 Another point to consider: if the plan is a prototype/VS and does not currently contain this provision, will amending to add the provision remove it from prototype (or volume submitter) status?

Yes. At least 2 prior discussion threads on this topic. Try the Search feature. My experience is: - retirees don't like change, - explaining the option to retirees will be much more difficult than you think, - the retiree acceptance rate will be low, - there is a potential for PR disaster, - the additional cost of annuity purchase is not worth the hassle of the above.

Data as of 29-OCT-10 (Friday) Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 4.75 4.75 Aa 4.97 4.89 4.93 A 5.21 5.17 5.19 Baa 5.70 5.86 5.78 Avg 5.29 5.17 5.23 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 0.19 Medium-Term (5-10 yrs) 1.06 Long-Term (10+ yrs) 3.08

Another discussion: http://benefitslink.com/boards/index.php?showtopic=46850

At least one of our clients uses a Cisco system. From my persective, it's simple and effective.

Might depend on who you are. Plan sponsor, auditor, employee of the TPA, etc.

Analogy: for Enrolled Actuaries, no CE credits earned prior to enrollment (look at the date on your certificate) will count.

Does the plan permit a partial distribution?

That Q has probably already been answered in the plan document itself. Do you know any way to retroactively change a plan year definition? Yes, it's possible to have two plan years beginning in the same calendar year. Check 5500 instructions.

For anyone who is not yet a participant, there are no protected benefits.

Normally, plan provisisons rule, assuming they conform to any limitations required by federal law. From your statement, it appears the applicable plan provision is the plan-imposed limit of paying "small" benefits only if less than $20K. That type of provision might be unusual for a 401(k) or profit-sharing type of plan, but it is permitted. Assuming I understand your facts (which is not necessarily a good assumption), you can ask that the plan be amended to permit your distribution. BTW, what do you mean "frozen"?

IRS Reg. §1.411(d)–3(g)(6)(i)) http://ecfr.gpoaccess.gov/cgi/t/text/text-...26/26tab_02.tpl

Carefully read IRS reg. 1.436-1(h).

A few thoughts, in no particular order: - Are you sure no AFTAP certification was issued? (No valuation on October 25 is not the same as no certification.) - If none issued, is any action required to accomplish "full restrictions"? - Participant notification? - If you issue a 2010 certification now, there is no impact on 2010, but what is its impact on 2011?

Did you read the posts and/or the FAB? As stated above, the AFN for the 2008 PY was sent in 2009; the AFN for the 2009 PY was sent in 2010. Etc.

Might help: http://benefitslink.com/boards/index.php?showtopic=45542

It's the earlier of the actual filing date or the due date.

Those disabilty rates look high to me. Might be company or industry specific. You will find some disability tables here (but no turnover tables): http://xtbml.soa.org:8080/xtbml/jsp/index.jsp Perhaps ask the actuary for the complete table?

TH determination is based on accrued benefits (DB) and/or account balances (DC). No imputing of anything. However, don't forget that Key Employee is not the same definition as HCE.

As of this posting, nothing on the IRS website. Last year, IRS news release 2009-94 was dated 10/15/2009. I'm not speculating about any hidden IRS agenda with the (apparent) delay. However, when they do release it, IMHO, we are entitled to an explanation.

You're correct. My booboo.

Based on my own experience, YES. (In years past, I've received a large booklet from a prior employer, coveering about 20 different plans, only 2 of which ever covered me.) For complete analysis, you may wish to review DOL reg. 2520.104.

Apparently, the strikers/rioters are bad at math.

No, the due date for distributing the 2009 AFN for larger plans is/was April 28, 2010.

See Q&A1 in DOL Field Assistance Bulletin 2009-01 http://www.dol.gov/ebsa/regs/fabmain.html