AndyH

Thanks. I assumed since nobody in my office had heard of a 1951 GAT table that "GAT" was a typo and should be "GAM" and that appears to be the case from the list of tables on the SOA site. I'll further verify but that looks right. Thanks again.

I'm looking at a 1989 Multiemployer DB document. It says that actuarial equivalency is based on "1951 GAT projected to 1964" Can anyone translate what that might be or if such a thing existed and if so where it might be locatable?

Thanks David.

Be careful advocating for credit balances. You might be confused with an evil doer..... and be wanted Dead or Alive.

"Note that these regs are 412(i) instead of 412(e)(3) because the regs were issued prior to the Code section designation being changed." Aaah. A _____ by any other name smells the same.

Thanks for the comments. The credit balances do seem to be the source of all evil (and wasted time) under PPA.

The final regs say that the Rate of Return calc (for credit balance interest accumulations) must take into account the timing of contributions and distributions. How are others doing this with regard to contributions, by actual time weighting of all contributions, or by a shortcut of mid year or beginning of year deposit assumptions? Said another way, is there a generally accepted approach to the weighting of contributions for ROR purposes under PPA?

Perhaps they could be classified by their personalities? A stands for ____

As a practical matter, how many documents have different annuity options for different distributable events?

There was a PBGC letter in today's newsletter on this subject. They are playing hardball. I am amazed that they can get away with this type of stuff still. Seems like the old days when the problem person would answer the problem resolution line.

Effen _____

Effen, I would agree that technically all the available annuity options need not be offered if the document so provided, but I would think that the life annuity option would - isn't that actually considered the QJSA for an unmarried person?

If you offer the lump sum over 5K, you must also offer annuity options.

Thirded. Consistent with how we do it.

We still don't know the "circumstances" of the situation. The cautions are appropriate, but this could be a non-issue if there is no past service grant and nobody that is not covered is non-excludable statutorily. It seems to me to be a legal matter best left to legal advice.

Thank you both, I agree. And your cite is right on David, thank you. Same thinking on top heavy?

In the post-PPA world, for a cash balance plan that is not subject to 417(e) whipsaw that defines the accrued benefit as the account balance, is it still necessary to convert the account balance to an annuity if the plan is being tested on an allocations basis (as part of a 410(b) test). Or can the account balance be uses as the allocation for purposes of determining the normal allocation rate? Opinions? Second question, is the pvab for top heavy testing the account balance? (Obviously this is a document question but the ones I'm working with are foggy at best on this issue and aren't necessarily PPA final form, e.g. Corbel).

Potential, sure. Facts and circumstances, right?

Mike, have you discussed your first point with anybody from the IRS, or heard any such discussion? I understand your point but this seems like an error of omission pending regulations (or corrective law) rather than something that was intentionally changed. (And of course in the past they tried not to issue regulations without supporting law but now that does not seem like a barrier)

Ah, the solution to all ills, especially sleeping disorders - the PBGC instruction booklets! Do we really think that if tuni doesn't know how how to evaluate the cost of a lump sum provision under PPA two years from 417(e)/funding "equalibrium" that he/she will be able to decipher the PBGC instructions and formulas! The answer might approximate Blinky's result. tuni, I'm told that currently annuity purchase costs are about 20% higher than lump sums. But that is right now, and the third option is paying an annuity benefit from the plan and that must take into account expected investment earnings, investment and interest rate risk, mortality risk, expenses, etc. so there are a lot of "what if's" to consider. Plus, the actual plan circumstances and longevity are critical. So you need to hire a 3 eyed fish to guide you.

This one qualifies among Gary's most interesting situations. Should be a reality show. Seriously, if the client does not want a 2009 deduction, why not have him file his tax return on time (if it is due 4/15) and make the pension contribution for 2009 in time for minimum funding but not in time for deducting in 2009, the old includable contribution rule. Doesn't that accomplish the client's objective?

Thanks. That is what I was looking for, a general description of how the process might best be undertaken by the plan sponsor. And I appreciate and agree with the cautions.

A Steve Martin quote comes to mind. I just watched a funny YouTube version of it.

I know this is a backwards question, so please skip the correction, but If a client wanted help figuring out how to reply to his auditor's written inquiry about why their FAS LTROR assumption is 7% (or 6% or 6.5%, etc.) in a 50/50 balanced portfolio, what might be some helpful approaches? Are there any "model" responses that could be considered. Assume their ISP does not define a goal for an asset return. In the old days, I would think that a reply might be that equities are expected to return u%-v% and fixed income might earn w% to y%, so apportion those to the asset allocations and you get Z%, but in the post-2008 world this seems a bit shaky. Anybody dealt with this? Any auditor "traps" to be weary of?

This is very useful; I'll probably get that App. Just one followup: Does it emulate the old version or the "junk" version mwyatt references. Just as an aside, FWIW, The Infinite Actuary offers on-line courses that are available (for now) only on an IPhone (or regular computer of course).