david rigby

Use the plain understanding of a quarter end date. Simultaneously, you've found sloppy plan drafting.

Southern Railway is now part of Norfolk Southern.

Very common for BOY valuations to ignore those who could enter during the middle of the year.

If there are many years of AE increase, don't overlook 415 limit.

Play nice.

Who is "we"? If you are the actuary, it's not your role to determine the discount rate. BTW, I agree with Effen's comments above.

First. Plan definitions Second. Administrative procedures. Third. If the participant believes the administrative procedure is in error, or in violation of a plan provision, plan appeal provisions.

Kevin, just an opinion: if the document is silent on vesting, you may have to look to other sources of information. Likely, the first source is whether there is a precedent for another participant. If nothing else is available, the result might be as you imply: vested at retirement date. However, if the plan has an Early retirement date (that applies to this person), it will be difficult to claim vesting occurs at Normal retirement date.

See IRC 3121 for definition of "wages". Note that (a)(5)(A) exempts payments from a qualified plan. Next read 3121(v) for references to NQ plans. Note especially, (v)(2)(A), and its reference to "substantial risk of forfeiture" (ie, vesting). Bottom line: NQ plan benefits are (generally) subject to taxation as wages. Hey, but I'm not giving you tax advice.

Agree with QDROphile: if the PA is satisfied that the plan did nothing wrong, then the plan should stay out of it. BTW, the FA does not already understand the points raised by Lou S? Uh oh.

Forgot to get the January month-end rates (01/30/15), but here are the results for first trading day of February: Data as of 02-FEB-15 Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 3.29 3.29 Aa 3.34 3.41 3.38 A 3.38 3.66 3.52 Baa 4.21 4.37 4.29 Avg 3.64 3.68 3.66 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 0.94 Medium-Term (5-10 yrs) 1.36 Long-Term (10+ yrs) 2.05

1. While checking on Andy's question, don't forget that 401(l) is the safe harbor definition of "permitted disparity". Other variations may be permissible, but they just aren't safe harbor. 2. Might be an error, but not necessarily.

The issue is stated as "can they keep their plan", but I wonder if the real issue is "can they keep a particular feature of the plan"? Just a hunch, but that particular feature might be a brokerage window.

BRF?

Neither you nor the sponsor can "bend" the calendar.

If the church is part of a larger denomination, there may be overall policy (not necessarily rules) that indicate certain level of communication to employees. BTW, even if not subject to ERISA, providing a "pension booklet" can be a good idea, whether or not you use the term SPD.

Good questions, that deserve lots of discussion. Just my opinions: 1. I expect the change to be effective after 2016 (could be 2017 or 2018), and the funding requirement will permit, but not require, a projection. For 417 purposes, it seems very awkward to include a projection scale; IMHO, also not appropriate. 2. I agree, a 50/50 blend of the funding tables is the likely result. I expect to submit more detailed comments, which I'm advised to send directly to Carolyn Zimmerman.

For many, it's difficult and tiring to read everything on a monitor. Errors and/or shortcuts can be the result.

Yes, indeed seek out competent advice. But also take note of inconsistencies from your original post: - If the sponsor really did go "out of business" (yes, this can mean different things to different people), then the plan may have been automatically terminated. - If there is no plan sponsor, it cannot be "brought into full compliance".

IMHO, one tax filing is insufficient, but maybe that's just me. BTW, don't forget to coordinate with the plan's definition of "spouse": 12 months?

Proof? Wouldn't you look to the definition in state law? IMHO, neither the Plan nor the PA should spend anything (other than trivial costs) on this.

Has the 2014 W-2 already been issued? If not, don't issue a corrected form, just issue a correct one.

What does the plan say? If the plan is silent, consider recommending that the plan sponsor amend the plan to remove any doubt.

Ah, the controversial "Carol Gold memo". Does anyone treat it as authority? BTW, a claim that "NHCEs may never vest" is pretty silly, since that applies to every plan.

... and it's OK to advise the (proposed) AP/attorney that the k-plan did not exist in 1995. BTW, you state "divorced in 95" but be careful that not to confuse "separated" with "divorced". It might not make a difference, but it could.