david rigby

Yes, yes, yes. I agree with My2Cents advice, which can be boiled down to "follow the plan". However, mbozek makes a very good point about whether the participant's question is an appeal of a benefit determination. Of course, that also gets you back to "follow the plan". Avoid any type of incentive outside the plan.

Not so sure about that. "within 12 months" is not the same as "completion of 12 months". Suppose EE is hired 06/15/14 (full-time) and entry dates are June 30 and December 31. The original post indicates the EE should enter on 12/31/14, doesn't it? BTW, check prior documents. It's possible this is a drafting error (which might explain your problem but not solve it).

There have been a few prior similar discussion threads. Here's one: http://benefitslink.com/boards/index.php?/topic/56082-terminated-plan-last-participant-not-responding/#.VGteOE10yUk

Also, it would be prudent for A to rethink why it wants to do this. The result might be unnecessary administrative cost. Or worse. It's easy to see that "...consider him as an employee of the other new firm..." can lead to incorrect service records.

Here is a current link to 80-229 http://www.charitableplanning.com/document/669148 Prior discussion: http://benefitslink.com/boards/index.php?/topic/12131-distributions-from-terminated-small-db-plan/#.VGErOk10yUk IRS Manual for plan terminations http://www.irs.gov/irm/part7/irm_07-012-001.html See especially section 7.12.1.20.2 To original poster: does the plan address this question?

Answering the original question, NO they are not the same. Note that the statutory definition in IRC 411(a)(8) has nothing to do with service.

... and those Enrolled Actuaries might be glad to engage in a service relationship with you. Expecting this for free seems presumptuous. To me, anyway.

Forget to get the 10/31/14 data, but here is the data for the second trading day of November. Data as of 04-NOV-14 (Monday) Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 3.89 3.89 Aa 4.00 4.02 4.01 A 4.08 4.24 4.16 Baa 4.70 4.77 4.74 Avg 4.26 4.23 4.25 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 1.34 Medium-Term (5-10 yrs) 1.93 Long-Term (10+ yrs) 2.79

There are a few prior related discussion threads, which can be found using a key word such as "brokerage" or "brokerage option".

john, Your concern might be valid, but I'm skeptical since the benefit paid was a lump sum. It seems to me that the actual damages have not been defined, nor is it clear who is culpable. While I'm not asking for the details, it seems that you might need to be specific in your definitions (not here, obviously).

The present value approach may be more complex than needed. BTW, from the original post, it's not clear there are any "damages", but that may not be relevant to anyone else.

That might be the correct interpretation. Only the document(s) can tell you for sure.

Similar (and longer) discussion here: http://benefitslink.com/boards/index.php?/topic/56416-form-5500-sup/#.VE_cBE10yUk

http://benefitslink.com/pr/detail.php?id=49237#.VE6HrU10yUk Attaboy Dave! And that picture is very recent.

I think Lou means to convey that if the plan termination (e.g., corporate Board action to formally terminate the plan) occurs after a stock sale, then the buyer (not the seller) is the company in charge of the plan.

Last year was later than average. Think "sequester".

Perhaps use an EOY valdate?

Agree, but watch out for existing QDRO's that have generic language requiring any additional benefit/feature to be offered to the AP. It may not be common, but it does exist.

This also depends on the anticipated cash flow. Don't assume it will be level every year. If sponsor thinks corporate cash flow in year 9 or 10 (for example) might be much lower (or higher) than in year 3, then plan for it, especially as Effen has suggested. Ok, this might sound simple or intuitive, but it's overlooked. Just ask the question.

Good comments above. Note that the word "retired" can have multiple meanings. In a qualified plan, it usually means separation from service after any date at which benefit commencement is permitted, and may also mean that the benefit has actually commenced. However, it may have other connotations under HR policies.

Agreed, but that will not stop the accountant for asking for a "SSAE16 report", exactly like many previously requested the actuary's "SAS70 report". I'm just curious about the extent of such requests, and how other actuaries have responded.

Any actuaries had inquiries from auditors w/r/t SSAE 16?

Does this help? http://benefitslink.com/boards/index.php?/topic/55523-beneficiary-is-minor-child/

As of today, Carol's chart includes this footnote: 2015 IRS limits are projected, courtesy of Tom Poje of DCS Retirement Group. 2015 Social Security wage base is projected, courtesy of Financial Ducks. Projections not yet available are shown as “N/A.”

Have you checked the plan provisions?