AndyH

Andy, are you talking about the CB plan annual addition or the equivalent benefit at NRA? I'm sorry, I misread the question. Yes, definitely .5% as an annuity, not the credit. I'm not sure if the .5% is current comp or average comp (in the case of a final average pay DB), that is what I remain uncertain of.

Andy, are you talking about the CB plan annual addition or the equivalent benefit at NRA? Good question - I intentionally omitted that detail because I'm not sure. I interpreted it as both, it was clearly within the context of whether the Schultz memo is still current thinking, but I can't say with certaintly one or the other. I'm sure others heard it - it was closing Q&A I believe. I'm pretty sure Mike Preston was there, and probably Tom Finnegan also.

Jim Holland said at the June 2009 Boston ASPPA/COPA conference that .50% is the IRS' current thinking on the appropriate standard.

Agree. Tweak it a bit and it can be tested as I described.

Agree, and also I believe that it would qualify under the "modified general test" of 1.401(a)(4)-8©(3)(iii)© that nobody has ever heard of including the IRS agent who recently reviewed one that we submitted. In the end he agreed. You won't find it on any road maps including the submission forms.

I think you can do as you suggest. As long as each component passes 410(b) then they would be uniform and pass a(4).

Seems to me the answer is a clear no, for the reasons my 2 cents states, until/unless the accrued benefit is reduced, which can only happen at plan termination through a waiver, or by a reduction in the accrued benefit by a distribution larger than the accrued benefit, maybe through a installment payment type of option.

Same here.

Andrew, is this really a bank, or is it a Trust department? If the latter, and they are experienced with pension accounts, they may have notification letters and procedures ready to go.

Yes, you must notify participants, but there is no specified format or timing requirement to doing so. Most include it on an SAR or AFN. If it's more than 30 days late, you may or may not have to file PBGC Form 10. And it may generate the need for an additional attachment to Schedule SB.

There's your solution jc. Suggest that the boss call VEBAPLAN to discuss the project! You might not have a job afterwards, but this issue will be off your desk.

Thanks. The attachments part makes sense but the truncation theory does not work in this case. In this case the percentage for line 14 would be 95.8707%. Line 14 is entered as 95.87. The error message results. p.s. Blinky, abanky is another of the 9.

Thanks. Will Robinson

Below is the validation error report on a 2009 SB that we consider correct and final (sorry I lost the column formatting). The items in bold (my emphasis) are of concern to us. Questions: 1. Do all validation "errors" result in filing rejections? 2. Anybody else having a problem with #14? Our entry is correct but we cannot get rid of the validation error. 3. Are the other messages harmless? Any help/comments on these items would be appreciated. Form Rpt Pg# Rec# Fld# On/Near Line# Message 2009 5500 Sch. SB 42 6 Warning - (DOL I-155SB) The Actuary (Name), Firm Name and Signature Date must be provided on Schedule SB. 2009 5500 Sch. SB 43 6 Warning - (DOL I-158SB) A copy of the signed Schedule SB must be attached in PDF format when a Schedule SB is provided. 2009 5500 Sch. SB 82 14 Warning - (DOL B-686SB) Line 14 must equal Line 2(b) minus the sum of Lines 13(a) and 13(b) divided by Line 3(d)(2) when Line 4 is not checked.2009 5500 Sch. SB 165 22 Warning - (DOL B-691SB) The Weighted Average Retirement Age needs to be attached when line 22 has a value. 2009 5500 Sch. SB 169 24 Warning - (DOL I-127SB) The 'Non Prescribed Actuarial Assumption' needs to be attached when Line 24 is marked Yes. 2009 5500 Sch. SB 171 25 Warning - (DOL I-128SB) The 'Method Change' attachment needs to be attached when Line 25 is marked Yes. 2009 5500 Sch. SB 173 26 Error - (DOL I-120SB) The Schedule of Active Participant Data must be attached when Line 26 is marked Yes. 2009 5500 Sch. SB 180 32a Error - (DOL I-132SB) The 'Schedule of Shortfall Amortization Bases' needs to be attached when Lines 32a or 32b has a value greater than 0. < 8 > validation errors/warnings were reported

What then is the problem? If the election is to a form that satisfies the QJSA requirement, and the cite you reference says it must be honored (which is the right thing to do anyways IMHO), and the plan does not conflict, what is the problem?

And I thought WDIK was our archivist. Maybe he's on vacation.

Can you be more specific about what exactly the plan does say? What type of document is it?

Thanks for your help Frank.

Thanks, but just to clarify, it is a government error? Clearly a lookback month is allowed for 2009. I'm just not sure how this works organizationally. Are these edit checks available online somewhere?

By evolutionary, do you mean nearly extinct? Do you know only 9 people passed the EA1 exam this year? Probably out of 40-50 total applicants. (Some did get exemptions and waivers of course).

Maybe GEICO is the insurer and it's so easy a caveman can do it.

Thanks for the feedback. I am told that the Webclient ?? rejects filings that have such validation errors so that the form cannot be filed. Again, I am passing this along; I don't know exactly how this works - I have yet to file anything for 2009- but I am told that a local Relius rejection means it cannot be filed. We have tried DOL and or EFAST to see what they say about 21B but have yet to get an informed response. We have not gone to Relius directly yet.

Is an actuary required to terminate a fully insured plan? Maybe that is the decision maker's point.

If the one participant is the business owner the plan would not be subject to the PBGC program so you would not file with them. You should have someone experienced review that but that is how it sounds. I don't (with limited exception) deal with 412(i) plans except to make fun of them, so I am not sure if they are even covered by the PBGC program. But one participant plans covering only owner/employees are not whether they are regular DB plans or 412(i) plans. p.s. Apparently 412(i) plans are not exempt from PBGC, they are just aren't subject to the variable rate premium that regular plans must pay. So you need to determine if they are exempt under the owner/employee rule.

Why are you filing with the PBGC? Is the one participant the owner/employee? Is a 412(i) even subject to PBGC?