AndyH

But who offers such a spreadsheet for sale?

Yes, you have it right for the current year measurement period pd methodology (@ .65%). Not particularly complicated.

Sorry, I will edit my question so hopefully it will make more sense.

So does that mean that Plan A (with 101 participants) that is 81% funded and had a 21% active participant reduction but had no plant or facility closing must file Form 10, but Plan B (with 101 participants) that is 81% funded and had a 21% active participant due to a plant closing is exempt? Does that make any sense?

Does anybody know what the third bold requirement means within the context of whether an active participant reduction might require the filing of Form 10 for a plan that is 80% funded? I have asked this here and elsewhere before and have never found an answer. Funding-based waivers: For the event year: - No variable rate premium (see Part IV.B); - Less than $1 million in unfunded vested benefits (see Part IV.C); or - No facility closing event/80% funded: The plan is at least 80% funded for vested benefits (see Part IV.D) and the active participant reduction would not be reportable if only those participant reductions resulting from cessation of operations at one or more facilities were taken into account.

David, we do this all the time with terminated plans, and would pay the 417(e) value of whatever annuity was payable, in your example the life annuity. Same thing as if you annuitized the person, you wouldn't purchase a j&s for a life only recipient.

The benefit that is tested is the change in benefit during the measurement period. The measurement period is the option, not the methodology. If the measurement period is the current plan year, then the eoy AB must be compared to the prior EOY AB, and a major amendment such as a past service amendment can easily make the test fail. Yes, it must be included. If the measurement period is the current year and all prior years that can lessen the impact of a retroactive benefit increase, or any benefit increase for that matter, provided that you can justify the testing service used in the denominator. The 5 year past service rule is a separate matter.

You need to test both the (NAR) 12/31/2011 Accrued benefit at NRA less the 12/31/2010 Accrued benefit at NRA. Sounds like $3 K. and then for the MVAR you need to test the QJSA equivalent of each benefit difference at age 55 12/31/2011 less 12/31/2010, each normalized. And then you can try accrued to date. Fun stuff. Reminds me of what I heard a prominent speaker at a conference say once (not my advice) - "just use what your software spits out for the MVAR since nobody can figure it out anyways".

He stated that it would be done through a corrective plan amendment. If no equivalent benefit is provided somehow, the plan would fail 410(b) and 401(a)(4) testing, from the information presented..

Yes would be my vote. Unless that is you wanted to argue satisfaction of the requirements through a PS plan that is permissively aggregated. But I would not try that since there is nondiscriminatory timing of amendment exposure. IMHO.

Ah, my one end of year val will be all set then!

But if you got two NRA's Does that make this wrong? Just repost here And (maybe) Tom'll give you another song.

What's the frequency, Kenneth?

Oh, and Effen's question I expect to be phase II of this issue in the future. Does a REA-only death benefit create a forfeiture upon death which requires the use of post retirement mortality? Who gets to decide?

No misunderstanding, unfortunately. The auditor is using a program, and we are given screen shots so we understand the difference in the numbers. There appears to be no option in the program not to use post retirement mortality, which has the effect of the l65/l68 adjustment as SoCal describes. We have not been able to elevate the discussion yet, unfortunately. Both approaches are widely used, I have learned.

The auditor is wrong in my opinion, since there was no risk of forfeiture from age 65 on. Try to look back thru the 415 regulations for an example of their reasons why late retirement adjustments ignore mortality after NRA. Their reasoning should carry some authority here. Thank you. And, yes, the 415 regulation does support this method for exactly the "non-forfeiture" reason, directly on point, both in the preamble and in the formal regulation section, and we are citing it. But the PBGC seems to play by it's own rules, so they may consider the IRS 415 regulation to be irrelevant since 415 is not an issue. We'll see.

Is the age 65 Annuity rate x (1+i)^3 / the Age 68 Annuity rate method (assuming age 68), for a plan that provides for a full pvab "wrong", as the auditor says, is the question.

Thanks. Hoping this auditor is a renegade - but don't know yet. If not, we won't be the only ones facing surprises of this sort - after the fact. What would your view be if the death benefit were a REA only benefit (not paid by employee)? Subjective?

A PBGC (post termination) auditor says the benefit must be increased with mortality. Formally, in writing. Looking for information for our counter-argument/appeal. (I happen to strongly agree with your comment about pre-retirement mortality, BTW, but not everybody does).

Just to be clear, does this sentence mean "defers beyond NRD"? Yes. I will edit to clarify. Thanks.

Small frozen DB plan provides a death benefit equal to the present value of the accrued benefit. Actuarial equivalence definition includes pre retirement mortality. Participant defers payment past NRD. Is the deferred benefit from NRA to a later age (assume 68) required to be increased with mortality (using D's)? Document does not specify and past practice was no since there is no forfeiture on death. I know there is past discussion of this, I have read it. The key word is required. FWIW, I think the IRS clearly says no for purposes of 415 adjustments. Opinions please.

We used to get help with fishy things from The Blinking One, but maybe he has found another pond. I have not found in the regulation where the second payment is not a new ASD, so I agree with the marriage issue being an issue. Other issues include how to handle post-70.5 for a terminee, what happens upon death, etc.

Thanks for your comments. The plan administrator does not want to offer a second ASD, but is it required? That is basically the question, whether a second ASD is required. I'll count your vote as a No. Thanks.

A plan with a lump sum provision becomes restricted and the participant wants to receive a lump sum benefit. May the plan state that the lump sum election is irrevocable, so that when the plan becomes unrestricted the unpaid portion is then paid as a lump sum without any optional forms of benefit (including a QJSA) being offered?

I see this a lot with takeover plans - no actuarial increase for vested terms., and no RASD. How does one suspend a vested term? I don't doubt that there is a requirement to provide an actuarial increase, it is just not in these documents and I don't know why. And I see it often with lawyer-written documents. Comments?