SoCalActuary

This topic is being asked the IRS by more than one industry source. However, a safe-harbor is a commitment of no more than 4.5% of pay using the match, or 3% for the non-match. The IRS is taking a hard line here, but they think these are small amounts.

Are you referring to Flexible Spending Accounts? Or are you talking about Funding Standard Accounts in DB plans?

My reply ended up in the wrong message group, on DB & DC deduction limits. So I will try again. Your choices are: 1.Learn vlookup function in Excel 2.Complain to your vendor 3.Hire your favorite consulting programmer/actuary to help you 4.Pick another vendor (suggestions available)

Sorry, that last message was intended to respond to another question.

Does your software vendor have a solution? You have other choices: Learn to use vlookup in Excel Contract with your local tech expert Change to vendors who can combine both plans (suggestions available if requested) Have an associate of yours or your consulting actuary help you.

By freezing the DB plan, you can elect whether it is offset by future additions to the MP plan. You do end up with vesting issues, but it is probably moot. The DB still provides a minimum benefit until distributed. We have used floor offsets which only use "new money" in a new plan or separate account of an existing plan. Similarly, we have used floor offsets that only use "old money" that ignores new accruals. But you could certainly use the entire DC account as an offset. With over-funding, you could also increase the participation span or benefit levels of the DB minimum plan to use up a portion or all of the excess assets, assuming you meet non-discrimination rules.