AndyH

I think that is it, B, you seem to be somehow crediting service or participation that will never get credited if the plan is "frozen". So the age 58 service or participation limit will remain forever applied as long as the plan is frozen.

That is what I was thinking. I went to the June 2007 Boston Advanced Actuarial Conference and there were good on-point outlines done for that, one by LD I believe. I'm sure they've been updated for the more recent conferences, but if not the 2007 ones could be purchased through ASPPA I would think.

What if it is a 412(i) plan, Ned's favorite? Same answer?

So you are testing a DC plan on a benefits basis, I will assume, and you don't seem to want or need to permissively aggregate the CB plan. If each of your rate groups are at or above 70%, I believe that you do not need to consider the CB plan at all. If one of your rate groups is < 70% then you need the Average Benefits Test and I believe that you must include benefits from all plans under this particular set of facts. And I think the same applies to the CB plan, that they need the DC plan data if all of their rate groups are not at 70%. If instead you were testing the DC plan on a contributions basis and the CB plan were being tested on a benefits basis then neither plan is being cross tested and you could in fact exclude the other type of plan entirely, as both Tom and Mike alluded to.

I took ABR to be Average Benefits Rate, whatever the technical term is. So I'm sure that is all this is - we're talking about different tests. perkinsran, please clarify.

Mike, how do you test them separately? Do you mean compute them separately and add the results together for the benefit percentage? This is an average benefits test, so I think Tom cites the rule correctly, with the added option of summing separately calculated results. Agree?

And, if anybody gets a committment from Relius on timing, please post that response.

Agreed. Good points as usual by the wet one. I'd still adhere to the rule I cited unless it causes some manipulation of results. Remember also that if you test accrued to date that only people benefitting sould have NARs in the test. Is this person benefitting? Is there an hour requirement for an accrual? A little messy there it seems to me.

If the person has no compensation, one argument is that such employee should not be in the test. "No compensation. Not an employee. Not in the test. Any test" I heard Jim Holland state a few years ago. That is what I have followed. Of course he or someone else may have changed their mind, but I think that approach makes sense.

But they got Caribou to shoot, don't they? Oh, and how would you do "aerial wolf hunting" without guns?

Their management is great. They even give you those pop-up surveys before you have even done anything on their site. Talk about being proactive! And they even invest in equities now, starting last fall I think. And they keep their premiums in lock boxes, and they change them often so nobody can find em. And they do on-site audits mostly in good weather and in vacation areas, so morale stays high that way. And they have the most convoluted missing persons premium calculation so nobody can figure it out and that helps motivate sponsors to find their missing people. And they used to be so efficient that if you had a problem with a rep you just called the probem resolution line and chances are the same rep would answer! And they have terrific memories; if you do complain they are certain to remember you next time you call.

I guess that woujld make it either an "ex-standard table" or a "table formerly known as standard".

Better than the old 412(i) rants with Dom? And the VUL rants with George? And Blinky versus Moe Howard? And the animal fight that Dave Baker had to break up? That one brings a smile.

My thanks to EF Hutton for completing my inadvertent half answer. Now, my zen question of the day. The 'applicable mortality table" for 417(e) is among the standard tables. Is it still standard even if it is no longer the 417(e) applicable table, e.g. is 1983 GAM M/F blended a standard table in a 2008 test?

Are cross border hockey games considered trade missions for foreign policy expertise evaluation purposes? Selling hot dogs on a cross border ferry perhaps?

Absolutely, if it is one of the "standard tables" in 1.401(a)(4).

Judging from the geography described hearin, all people from Detroit must be foreign policy experts.

This might be more eloquent and less confusing if referred to as "flame throwing" rather than burning.

flosfur, I have to respectively disagree. 1.410(b)-5(e)(3) is a testing option, not a plan aggregation rule. Pensionpro's cite is the starting point to determine the coverage group, which I do not disagree with. 5(e)(3) is a testing option once the coverage group has been determined. We'll have to agree to disagree.

I am far from fluent in it, but you might pass the safe harbor cash balance provisions of 1.401(a)(4)-8©(3) and avoid testing.

Can? Sure if is meets the gateway requirements. Should is another matter altogether. It is not at all clear what the issue is that would make you consider this.

BTW, I don't think it is clear that you can use SSRA in the test.

So, it bites, but it's not your dog, is that about it?

So, your dog does bite.

But there is no ceiling, so people that I have spoken to are not willing to guarantee a 6.43% return in this environment with no cap. Would you?