SoCalActuary

Did the piloting ever get the actuarial to agree? (Adjectives galore)

Plan document says one month lookback to determine 417e rates. It is early in January and the December rates are not yet entered. Any good guess on the rates? It looks like they will be a small amount higher than November rates. A participant wants their lump sum right away (probably to use their LS for immediate bills). 25 year olds have no understanding nor patience.

This sounds wrong. If the prior year benefit was 60% of average pay, and the current benefit is 70%, that is a 16+% benefit increase. AE at this age does not reach 16% increase.

Sue for abandonment and divorce, says this non-attorney spokesman

So long as you get to 100% after 3 years, yes.

I never saw DJ mention "percent of HCE vs NHCE" affected. His facts say all 8 NHCE are going to be covered, so we may be beating a dead horse, but discrimination is not about counting one for one.

Not really. Just do it. Additional service may result in increased accruals. On your reduction of benefits, do you have actuarial equivalence increases for deferred retirement. If so, that basically makes the payments neutralized.

Participant made the mistake, and trustee executed the instructions from the participant as written. I am wondering if the trustee has the authority to reverse the transaction, also considering whether the trustee even wants to.

Being 412e3, you do not get the judgement of an experienced enrolled actuary, "because it is not needed", and the CPA / agent keeps control. But if you discontinue the 412e3 structure, you have to decide if the future payments to the policy will continue within a cash balance structure. So I suggest you modify the policy to reduce or eliminate the unneeded death benefits you pay for, but keep paying premiums for cash value buildup. This will avoid the surrender issues that come from cancelling the policy. If your agent won't do this, switch to a new agent who will, and inform the insurer. Cash balance plans are well suited to your goals of funding your retirement target sooner rather than later. You can keep your rebuilt annuity contract within the plan while funding the additional benefits within a trust.

You are making the assumption that the benefits will be forfeited (not taken) for two years. I believe the IRS calls that a bad funding assumption, essentially a reduction in plan benefits. Certify the underfunded as if the benefits are payable at 62, and you get the desired result for a26. However, this also adds funding requirements, which is the logical choice anyway.

Participant has existing accounts in 401k plan and wants to convert part of the pre-tax accounts to in-house Roth, accepting tax consequences. They get sloppy and check the box to convert all of their account. Trustee has completed the transfer in the past few weeks. Participant realizes their error and wants to reverse the transaction. Trustee wants an opinion on what is allowed and what is taxable. Simple answer would be that it was already done, no looking back. But can the Trustee allow the correction and restore part of plan accounts back?

The plan sponsor has an insurable interest if they would suffer an income loss by the death of their employee. Maybe they also have some form of severance liability to the insured's family. Now there is also the taxation issue of who if any paid the PS-58 cost, and how they recover their investment?

The simple issue is about adopting employers and recognizing service. If this is still the same plan, you add Corp B as an adopting employer. When Corp A closes, you need to make sure that credited service from Corp A is recognized. And you amend the plan so that Corp B is now the Plan Sponsor.

Can they use the past service? It appears they already have service in this plan from employment in Corp A. The owner is still a participant.

Extending this issue: one person DB plan was frozen in 2013. New employee hired in 2015, and would be eligible in 2017 if plan not frozen. No intent to provide benefits for new employee. Does this comply with 401(a)(26)? A prior thread says that you need to comply. The one-person plan is top-heavy, but owner is getting no new accruals. So the issue appears to be: No new participant, new participant with a minimal accrual, or new participant with topheavy accrual?