david rigby

I'm available to provide some actuarial services. Better me than Ned.

Possibly this "hybrid" is already a prior change; perhaps the plan offered unlimited LS until X date? If so, that is defacto evidence that 411(d)(6) was considered when it was changed. You may not like the option, but if it's there for 411(d)(6) reasons, you've got it (unless all affected participants are now gone).

At the end of December, Moody's Aa rate was 5.72%. At the end of June, it was 6.10%. Can we assume that market rates are 40-50 basis points higher? Maybe. Although that may not be the best technique to determine a discount rate, it can't hurt to include it in the discussion. Of course, you can find your own discount rate by doing some cash flow matching; not necessarily easily done, and possibly not worth the effort.

Go for it.

Are you sure it's a money purchase plan? Are you sure the plan/sponsor is subject to the J&S rules?

404(a)(4) issue?

Of course that is the silly example. But sometimes, XYZ Actuarial Co. assigns Actuary B because Actuary A is no longer employed with XYZ. And the IRS does not draw a bright line between these situations.

You can complete the form via this link (save and print on your own network). http://www.irs.gov/pub/irs-pdf/f5558.pdf

Perhaps I missed it somewhere, but what kind of plan is this? DB or DC? (Some of your description sounds like a DB plan, but such cannot have "separate accounts", or any accounts for that matter.)

Maybe. Is that employee a participant? Is that employee over NRA? (See parenthetical phrase in second paragraph of "FACTS", or second sentence of second parargraph of "ANALYSIS".) The default is to assume the severance of employment is ER-initiated. However, finding an employee embezzling from you (for example) does not mean a firing is initiated by the ER. Hence the last sentence in the second paragraph of "ANALYSIS".

ERISA sec. 4041(e) is part of Title IV-Plan Termination Insurance. See section 4021 for plans which are exempt from the entire title. If your plan is exempt, see IRC 414, and search these Message Boards for similar discusions (there are several).

I've seen nothing since, GrayBook or otherwise. There are several discussion threads on this topic on this Message Board, but they will likely point you to the same result. Although it sometimes (not always) seems silly, I see no reason not to follow the advice in Q&A 92-36.

June 29, 2007 Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 5.73 5.73 Aa 6.12 6.08 6.10 A 6.24 6.30 6.27 Baa 6.46 6.78 6.62 Avg 6.27 6.22 6.25 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 4.86 Medium-Term (5-10 yrs) 4.98 Long-Term (10+ yrs) 5.19

REA: August 23, 1984 (or thereabouts) If the plan does not charge the participant/VT for the cost of the pre-ret death benefit, I think the answer to the original question is "No".

When you searched PPA for this issue, what did you find?

I doubt that a partial termination requires a plan amendment. However, there may be circumstances under which such amendment would be useful, especially if there is any question of who the "affected" participants are. Beyond doubt, this situation requires some good (but probably simple) documentation in the files of the TPA, the Plan Administrator, etc.

Would that be 3 loans? What does the plan say?

Duplicate post. http://benefitslink.com/boards/index.php?showtopic=35907

Be careful about settlor vs. non-settlor functions. Is it possible that this person did some of each?

Depends on how close you need to be. Simple is to calculate 1/1/07 PVAB, using your best estimate of 08 417 interest rate (phase-in starts in 08) and mortality, and then roll forward one year. Then adjust for different expected payment date.

(f) liquidate that particular asset and invest in something whose value is never in doubt?

This may not be a violation. Tread carefully; hitting the comp limit is not (necessarily) a trigger to cease elective deferrals. (I'm assuming this is a 401(k) plan.) Suggestions: Review the plan document. Search these Message Boards for more discussion.

No. It is a choice. The employer chooses to cover, or not cover, dependents based on a specific defintion. You choose to get married, or not.

May 31, 2007 Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 5.57 5.57 Aa 5.97 5.96 5.97 A 6.10 6.15 6.13 Baa 6.35 6.65 6.50 Avg 6.14 6.08 6.11 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 4.81 Medium-Term (5-10 yrs) 4.87 Long-Term (10+ yrs) 5.07

abanky, If it helps to have consensus, I agree 100% with Effen's comments.