AndyH

Sure there is silly unless you didn't have an accrual during the year (and why do the plan if that was the case?). Remember the UCL calculation is considering benefits accrued through the end of the year. Read Q&A-9 of the Notice. It should clarify for you what you are allowed to fund when DC contributions don't exceed 6% of pay. By the way, what do you mean by "funds 100% of the DB contribution"? I submit that he who uses the term "clarify" and "Q&A-9" in the same paragraph has been in the sun and heat too long. ttott, the red fish is of course correct despite his color. It sounds like you do need to brush up on how current liability affects the minimum and maximum db contributions. In short, without 404(a)(7) the db minimum becomes the greater of the old minimum or 150% of projected unfunded current liability EOY. With a <6% DC contribution covering the same people, 150% becomed 100%. CL increases due to amendments affecting HCEs within the last 2.999 years need to be backed out (the 2.999 or 2 or 3 remains a bit foggy to me). As to this proposal stuff, you should not IMHO have been quoting 150% of current liability as the proposal figures to begin with. If you were, you may have a problem. If not, I don't hear one. (This reinforces Blinky's point to his 7/9 6:53 comment) Hope this helps.

I know this is only academic, but I would add that the qualifed replacement plan option is available only in connection with the termination of a qualifed plan, not a "rollover" or "transfer". Only the surplus assets are transferred. The terminating plan benefits are distributed in accordance with the termination.

You win. The series of tiered rates are still used, so your argument is persuasively logical. Oddly enough, reading through some the the PBGC proposed regulation "background", there would seem to be many plans that still use the old PBGC rates. Thanks for your help.

Thanks. Had to re-read that a few times. You say no "indexing" of the mortality table based upon the whims of the "mother ship" without clear client assent. So UP84+1 still rules. Right?

Non-ERISA DB plan pays lump sums which are based upon the "PBGC Interest Rate" and the "PBGC Mortality Assumptions" The Plan document defines the latter as: “PBGC Mortality Assumptions” means the mortality assumptions used by the PBGC in valuing immediate annuities of a terminating single employer plan. This is interpreted as UP84+1. Is this correct in 2007? Opinions please. Thanks.

Geez. Tom (P), you must have a few goat jokes or goat-a-grams you've been waiting to use, no? The correct technical answer is that if the kid looks like the one on the AFLAC commercial then he is statutorily excludable.

Had to look up AAMOF. I was concerned for a moment that it might be along the lines of FYIFV

Terrific DB discussion, BTW. Surprised pax didn't "prune" this to another board.

Good edit. Lesser was intended to be greater. I'd edit my post but then Austin Powers might attack me! Well I'll have to chance it.

This all presumes that the $149,000 is either a 412 minimum or not more than 100% of current liability, right? In other words, you cannot contribute a dc contribution and more than the "minimum" to the DB where the minimum is the greater of 412 or 100% of CL and the combined total exceeds 25% of pay (per the Notice referenced). Edit: lesser was edited to greater. OK Austin?

I looked into this a few years ago and there are some posts on this topic. My recollection is that I concluded that such an offset may be ok for plan purposes, but the offset could violate labor law. I know this is ambiguous. It is meant only as a caution to cast a wider net than you may have otherwise been inclined to do.

Thanks. That is very helpful.

Thankfully (thanks to Tom) I can confirm that I did not imagine that discussion. See for example Q&A 7 from the 2007 EA Conference Blue Book. This is accessible from the practicioners section of pbgc.gov. Apparently there was similar discussion at a 2007 ALI-ABA session also. Apparently the IRS is accepting this position (at least for now). Sounds to me like the current answer. But it also sounds like it may or may not be the "final answer".

Maybe if you are extra nice JanetM will tell you what she pays her consultanciests.

What then am I to do with my moon rock collection in my brokered 401(k)?

The software poll posted here a couple of years ago did not indicate that ASC had a cash balance module. Presumably that has been added? Do you have to run the plan in both the DC and DB modules in ASC to run a cash balance valuation? That is what Datair requires I am told.

Unfortunately it is only anecdotal. I am 99.9% sure that I heard that conclusively stated at the ASPPA sponsored Advanced Actuarial Conference in Boston on 6/6/07 in the closing Q&A "Ask the Experts" session, but I don't know who stated it and I do not see it in the printed Q&As. Tom Finnegan was on the panel so maybe he could help out if you want to email him. Carol Sears was also.

Thanks for the comments. I get the impression that there are fewer cash balance practicioners out there than I thought.

Does everybody use their own software for cb administration and testing? The silence is deafening.

Looking for comments on pros and cons of commercial software available for cash balance administration and testing. Looking for user friendly menu driven system. The system would not have to handle non-CB plans. Thanks for any help.

Austin's sucessfully firing rockets out of all barrels with that reply.

Seems to me you have pension and non-pension issues. Pension issues would include the need to test these optional forms of payment under the benefis rights and features rules of 401(a)(4). That would be pretty weird but I would imagine that could be satisfied. But then you have the 411 accrual rules which (in part) say that an accrued benefit cannot decrease on account to advancing age or increased service. You might have an issue with the age. Would there be 411(d)(6) cutback issues if you denied a benefit that was available previously. I would think so. So, this is just one opinion, but I think such provisions would violate 411. And I would think there would be more non-pension discrimination issues that woud be more problematic. So, one opinion is NO. p.s. The 12 month election would not satisfy the QJSA rules IMHO either.

Austin, You are hairy, like an animal!

The controversy behind the interpretation of being a "beneficiary under a Trust" under 404(a)(7) is what I was trying to cynically contrast. I guess it would help to get the words right. Blinky, you look swell.

I cannot imagine how that would be permitted. Do you have an example?