AndyH

Thank you.

Holland Wickersham Pippins and probably others have all said at EA conferences that I attended that 417(e) includes a mortality discount pre-retirement, regardless of the plan's pre-retirement death benefit. They have also said that you didn't "have to" use mortality because using interest only would yield a higher result and the 417(e) result is a minimum. Of course that was before the reg relief for most valuable benefits only applied to increases required under 417e....I am checking the grey book to see if it is in writing and will see if there is a similar way to search ASPPA QA questions (ie Ask Larry Starr or Tom Poje)... Its interesting that you refer to the plan doc rather than the death benefit. The rules compare the results of the 417(e) calc to the results of the plan rates, The fact that the plan has a zero "q" for all pre 65 ages in its actuarial equivalence shouldn't change its 417(e) result, to my knowledge. However if for 417 purposes the plan says that if the form of benefit is a form subject to 417 that the result will be no less than if the applicable mortality table and applicable interest rates replaced the interest and mortality table in the actuarial equiv section, then there is prolly an arguement that the plan requires the no-mortality 417(e) calc, but that woulfd be a plan requirement not a 417e requirement Assume two plans identical except that plan 1 has actuarial equivalence of 5% interest; post ret mortality 1983 Iam; pre-ret mortality none Plan 2 has a table of conversion factors for all forms at all possible ages based on the identical assumptions.... The 417(e) benefit for these two plans has to be the same....doesn't it??? The QA at ASPPA annual will address the most valuable question and, as a follow up, I will ask this specific question. Most of my small plans do not apply mortality in the 417(e) calc and are specifically written that way and I am concerned that they will (or do) have most valuable benefit issues. Anyway to answer your questions...I'll try to find it in writing, but have heard them say it many times Not a PPA issue...they've said it for years Tom, what are you referring to by "the reg relief for most valuable benefits only applied to increases required under 417". Are you referencing the (at least to me) elusive TAM of last year? Or something else?

Now that the Jim Holland issue is resolved, I am still stuck on the 6% issue. Is a DB of 21% and a PS of 10% entirely deductible or must the DC be limited to 6% if the combination exceeds 25%? (Context is 2007 and a non-PBGC covered plan)

There are many old discussions about the notices. Those of us that remember MGB will recall he cleared this up. I was as confused as anybody about this before then. There are (1) PBGC reportable event notices (2) PBGC Notice to participants that expired 12/31/2006 and (3) an ERISA notice. The ERISA notice is due in accordance with regulations to be issued by the Secretary of Labor. Those were never issued. There is no clear ERISA notice due date. Perhaps the 2008 notices being drafted will clarify the due date.

Earlier white paper from the economists at the Treasury Department.http://www.treasury.gov/offices/economic-p...urve_020705.pdf Were these people on the Grey Goose bus?

Thank you.

If I may hijack this for a minute...Similar question..... Mike, maybe this is for you, but when testing a CB plan under the DB/DC general test combo rules, are we in agreement that for gateway purposes the CB allocation is first converted to an annuity using plan rates (perhaps 5.5%), then the annuity is valued at testing assumptions which might be 8.5% and UP84? This might, for example, make a $100,000 CB allocation be equivalent to a DC contribution of $55,000 for purposes of determining the minimum gateway. This seems to be what people are doing. Is it correct?

The gunshot you just heard came from my software vendor's office.

I thought I was sane until I started and find that I cannot stop paraphrasing Larry D. to clients when commenting upon PPA. In a session this summer, he called it the "Grey Goose law", something that results from tossing some IRS people and some economists into a bus and sending them off with many bottles of vodka. That about explains Belgarath's excerpts of the regs that come from PPA as well as PPA itself.

NO, that was just your favorite Red Sox minor league team's season; when your season tickets ran out.

....... and DB people around 2012 or so.

B, that was like a complete game shutout.

What is reasonable about any of this? Who retires at age 55? Even if the plan has a NRA of 55, does that make it a reasonable ARA for funding? Just a thought. But Calavera's idea is interesting otherwise. Same reasonable assumption issue though.

wish I could use past tense.

Thought you looked a bit discolored there Blink. Guess it's just a bit of sunburn from the last regatta.

It is the new online premium payment/reporting system that all plans subject to PBGC insurance (i.e. most DB plans) are now required to use in lieu of paper forms. Most are first subject to this for filings & payments due 10/15/07. I'd love to know how much it cost to build and maintain. It is a precurser to mandatory electronic 5500 filing, but with many added complications such as account and payment components.

You were of course the inspiration.

Lyrics for: When The Levee Breaks – By Led Zeppelin If we keep on filin’, MYPAA’s goin' to break, When MYPAA Breaks I'll have no place to pay. Mean old MYPAA taught me to weep and moan, Got what it takes to make a pension man leave his home, Oh, well, oh, well, oh, well. Don't it make you feel bad When you're tryin' to file your form, You don't know which way to file? If you're filin’ by email, There ain't nothing you can do; If you ain’t filin on time, There's DC to call or P-Jail to do. Cryin' won't help you, prayin' won't do you no good, Now, cryin' won't help you, prayin' won't do you no good, When MYPAA breaks, mama, you got to move. All last night tried MYPAA and moaned, Thinkin' about my forms and my happy home. Going, going to P-Jail... Going to P-Jail... Sorry but I can't take you... Going down... going down now... going down.... In honor of MYPAA's being down the morning of 9/27/07

Doesn't this upload and voucher system require that the actuary/TPA enlist as filing coordinator? And doesn't that require an escalation in potential responsibility/liability? That is the concern I've heard in some circles. Does anyone share such concern?

I don't think PBGC counting is any longer an issue. It is clear that zero accrued benefit people can now be excluded (I don't think this was true a few years ago). The participant count item is still an issue for other ERISA purposes. I don't think you can amend out their right to an SPD, to be counted for 412(l) purposes, for audit purposes, etc. Pre-EGTRRA it was also a top heavy issue. So, yes, the importance is dwindling and the PBGC is sooo forward thinking.

That's it. I'll call the problem resolution line and complain. I'll probably get the same person that gave me the bad info, just to save me time. They're very helpful there.

I think this is a fairly recent change on the part of the PBGC to allow these people to be excluded. Other than that, I would not "not count" such people without legal advice or affirmative informed client instruction. I think this used to be a common "error" that is no longer as common, but I have seen it many many times.

It is clear to me that this prior "vendor" needs to have his sausage sandwich grilling license revoked and go back to selling lemonade.

Thanks; I'll assume my colleague did something wrong. It would be nice if the PBGC practioner hotline person knew this.

Well, I have a client with no computer or email so I called the PBGC yesterday about this and was told that the solution is to obtain the PA's permission to perform all of the functions, including signature, and them mail them a paper copy "if you want". Merlin, I heard that what you suggest was in the instructions somewhere and that it might avoid the signature but a colleague told me today that he did try what you suggested and was required to sign electronically. Confused.