AndyH

How about 412(l), FAS#87 additional/minimum liability, 417(e), 1.401(a)(4)-(5)(B), PBGC Form 1 Schedule A for starters?

DBguy, How many small business owners or HCEs are currently allowed to take lump sum distributions from their DB or cash balance plans when they attain retirement age? How many plans are 110% funded on current liability basis after their distributions? We should not forget the substantial problems that need to be fixed in the DB world. And these problems aren't going away soon. Remember, we're in the middle of the perfect storm.

It might be useful to inform them to expect a DOL audit since it is a disclosure item on the 5500 filing series, and the accountant's opinion if there is one.

And let's thank Mr. Pomeroy: http://www.house.gov/pomeroy/prworkersnocover.html

No, he promised it would not pass and referenced an ASAP to be issued later that same day. The links to that were posted earlier in this thread.

Thank you for your efforts, Larry. Go to it. Brian promised me in an email that this will not pass. I believe him, but it will take maximum effort.

Bankrupcy law will soon become hot again; start mass mailings to TPA firms. I'd put my money on ASPA before I put it on the Democrats to preserve 401(a)(4) and "pension reform". Remember that victory? We hardly knew ye. But this will be a real uphill battle from the comments that I've read so far.

But how strongly do AAA and ERIC object to it, since it has no impact on DB plans, and how much impact would it have on plans of large employers other than DB's? As Mike Preston said, it is the actuaries full employment act. Who is going to oppose this strongly enough to make it fail, other than ASPA, which will become the incredible shrinking organization if this passes? Maybe I should rephrase this, since the Democrats will oppose this, but for different reasons. Who is going to be able to fight and maintain something close to the status quo is the more appropriate question. The fact is that business planning will mean lots of layoffs if this drags on too long.

ASPA just came out yesterday "We must and shall prevail". http://www.aspa.org/archivepages/gac/2003/...3/asap03-03.htm

Mwyatt, I wish I could agree, but this is just like TEFRA; budget deficit savings at the expense of retirement plans. I think it is central to the budget.

I find it astounding that such a secret can be kept so quiet in Washington. And what is scary about it is that the reduced tax deductions would seem to be part of the fuzzy math central to the entire budget.

Imagaine how many problems would be solved if they changed the "applicable interest rate" to meet the requirements of a "standard" interest rate, i.e. 7.50%-8.50%.

Sure it does. The spouse's component's R/P is 3/5 / 1/2=120%. Your analysis is correct. Everything passes.

Were all the industry advocacy groups asleep at the switch? This is from ASPA's most recent newsletter, about the Economic Stimulus Bill: "The acceleration of some of the limit increases passed in EGTRRA .......and an increase in the required beginning date for minimum required distributions (e.g. 70 1/2 to 75) are some of the pension proposals currently being considered for this package" Huh?!!!!! This is from the "Washington Update" section!!!!! Not a word about wiping out all DC plans as we know them and putting most of the people in this industry out of work.

I don't think we are connecting. Sorry, but I have no idea what you are saying. Care to explain?

I don't know if I understand your question or not, but yes I think you are right. If the 5% group passes coverage, it can avoid rate group testing because it is a safe harbor. But the plan as a whole still might be subject to the ABPT if any of the other rate groups are under 70%.

jk harvey, You must test the component which includes the spouse for two things. First, you must make sure that such component passes coverage by treating the other component people as not excludable and not benefitting. And generally you must pass ratio/percentage in this test. Then you must also pass rate group testing for each rate group in the component plan. In this case there is probably just one component, at 5%. So just because you have a component with a 5% formula does not mean that it passes; it must satisfy coverage and rate group testing. And remember that if all rate groups are not at 70%, you must proceed to the average benefits percentage test, which includes deferrals so this could be a problem in some cases. And regarding document language, you simply name one group as, for example, owners, or physicians, and the second group all others. And if you want more language detail purchase Sal Tripodi's outline, which is excellent. I did. It cost $195 and is available here: http://www.cyberisa.com/erisa_docs.htm

well, I voted for Bush last time, but not next time. No way I'll vote for Bush after this..........or Hillary, or Lieberman, or Evans, or Kerry or Gary Hart; certainly not Gephart or Daschle; certainly not Sharpton .............hmmm. Does Ross Perot support this proposal? Maybe Powell will have quit by then and be available?

Who's idea was this, and what are their email addresses and phone numbers? and p.s., Mike that was more true when the applicable interest rates were above 5% and before 15 years of negative legislation and regulation.

I'm going to dig out the cross tested final regulations and see if I can unscramble the coded message that says "payback's a bitch"!

It'll make this message board and 3/4 of ASPA disappear, among other things. Hope they're on top of this.

Relax, it must be a hoax perpetrated by Ted Kennedy. Good hoax, Ted!

Where is ASPA on this?

Would you describe the program please? Does this program include increased or subsidized retirement plan benefits?

Excellent point. Thank you.