david rigby

Does the Plan have to do anything? Whose problem is it?

... and of course, - the Plan document must permit the payment of expenses; - the expenses paid are reasonable.

It's not like the pre-PPA full funding limitation; no such "deemed amortization". The Transition Base, or a Prior Service Cost base, is amortized in a staight-line manner. Could be affected by FAS88, but not as you suggest.

Usually, the AOCI increase is due to an increase in the Unrecognized Net Loss (which is amortized in future years). Therefore, bad. (But, there may be other things going on.)

If the EE terminated employment during the plan year in which the plan termination is effective, you may get a different result. Check the plan document carefully.

Then why not turn off the CapsLock key? The answer to your question depends entirely on the precise wording of the amendment, and how it interacts with other plan language. It may also depend on the termination date(s) of the affected EEs. Yes, that means that some of the "partial distributions" might get 100% vesting and some others might not. The Plan Administrator probably needs advice of experienced ERISA attorney.

Most actuaries (me included) prefer to be paid for our work. Just guessing, I suspect that the actuary for this plan is in the same category. I could, but won't, provide a swag, primarily because the answer (even a ballpark range) depends on several factors.

Yes, that's why a document must be in writing. If the sponsor wants to do something different, the document must first be amended. All documents have a procedure (or general outline) of how to amend, and who has authority.

Data as of 31-MAR-10 Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 5.32 5.32 Aa 5.68 5.55 5.62 A 5.89 5.80 5.85 Baa 6.25 6.37 6.31 Avg 5.94 5.76 5.85 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 0.74 Medium-Term (5-10 yrs) 2.48 Long-Term (10+ yrs) 4.22

... And get multiple quotes.

Sounds like a failure to follow the written document.

Follow the plan document. BTW, the plan sponsor (or whoever has the appropriate authority) can amend the plan to add this provision.

Have not checked the statute, but I read a summary that indicated it is effective for "plan years beginning on or after 09/23/2010".

Indeed. Consider also that you may eventually follow instructions of both. If B controls the existing plan, then A (probably) has no authority. In fact, A might not be the trustee any longer. But A may wish to create a new plan for the new company. Very often, there are more facts than first presented.

Possibly deceased? http://ssdi.rootsweb.ancestry.com/

This question can be best answered by the plan's actuary. Or you can hire another actuary for this analysis.

IMHO, this is a good example of a need to change an assumption, no longer assuming that an HCE will get a lump sum.

See IRS Reg. 1.436-1(h)(4)(B).

Not the same as an IRS admission that they were wrong.

You're correct. Thanks.

Basic principles: - Create a 100% J&S at (current ages + 10). - Discount this by 10 years interest, and 10 years of survivorship for both. - Add a 10-year certain. If you have varying interest rates, the algebra is more complex, but same structure. Something like: a(angle 10) + v^10 * 10px * 10py [N(x+10)/D(x+10) + N(y+10)/D(y+10) - N(x+10:y+10)/D(x+10:y+10)] Please check. I'm rusty w/r/t commutation functions.

Call or e-mail me, please.

Sound like a good reason to require a plan document to be in writing.

Whether or not you are successful convincing the sponsor that some action is needed, the previous advice to resign as EA is the best approach. As SoCal correctly points out, this sponsor will probably object to any of your services that cost him/her money, anytime in the future, no matter how competitive your pricing may be. Alternatively, get paid first.