AndyH

Some of this is a bit unclear but I'll make a couple of comments. 1. If he turned 70 1/2 in 2016 then he has a RMD due for 2017 that must be paid in 2017, not 2018. No, you don't get 4/1 twice if this is the question. 2. If he does not get paid a full lump sum in 2017 then I would think he needs to take 12 months of payments in 2017, just like 2016. I'm not certain of this if he actually elected a lump sum but did not receive it. That would take some review of the regulations, but my guess off hand is that both election and payment would be needed in order to use the account balance method. 3. I don't think any later waiver affects #2 or #3 for 2017. Hope this helps.

Nice to see a Blinky Post (although I disagree with his initial comment - which didn't happen often) I bet this subject has come up on the ASPPA listserv if someone wants to research it.

Unless you do a corrective amendment and add benefit accruals sufficient to pass a(4) and 410(b). By 10/15 that is, under the normal rules.

It is common to add the same disclosure as a footnote to the AFN.

This is a DB, not DC, issue.

Hash balance plan?

Congratulations to Mike Preston for willing the ASPPA/ACOPA Distinguished Achievement Award. And many thanks for your years of contributions to these boards. ----------------------------------------------------------------------------------------------------- August 23, 2017 -- The ASPPA College of Pension Actuaries (ACOPA) honored Michael B. Preston, FSPA, EA, MAAA with the 2017 Edward E. Burrows Distinguished Achievement Award at the ACOPA Actuarial Symposium held in Chicago Aug. 18-19. The Edward E. Burrows Distinguished Achievement Award is presented annually to a pension actuary who has gone above and beyond in forwarding ethics, education, beneficial legislation or regulations that enhance the private pension system or the professionalism of enrolled actuaries within the private pension system. “Mike Preston’s history of service to the actuarial profession made him an obvious choice to receive the Ed Burrows Award.” said Joe Nichols, former president of ACOPA and chair of the Ed Burrows Award Committee. Mike is currently President and Chief Actuary of Preston Actuarial Services, Inc. Mike has been an Enrolled Actuary for over three decades, and an ASPPA member since 1988. During this time, Mike has served in many volunteer capacities, including as a member of the ASPPA Board of Directors, editor of the Pension Actuary, and member of the Actuarial Standards Board Pension Committee. Mike served as President of the College of Pension Actuaries at the time the combination with ASPPA occurred, and became the first President of ACOPA. Mike is a frequent speaker at ASPPA, ACOPA and other actuarial conferences, and is the founder of ACOPA’s member-only listserve — an invaluable resource for hundreds of enrolled actuaries.

Dave, I think that icon appears only if you are logged in. I could not find it until I realized I was not logged in. I agree the new view is difficult.

Nope, I just did some important research that says that she signed black bats with a golden pen in Jacksonville for the Jacksonville Suns in June of 2001 at that "Tonya Harding night". Tom were you there, perhaps hosting?

Just not the assets

I don't see why there is an issue with a participant not taking advantage of a subsidized benefit in a frozen plan. While the person is active, he/she does not qualify for the payment. If terminated, the language in the document should be read carefully and all required disclosures (at a minimum) should be sent to the participant.

Just seeing this thread. A late congratulations to Belgarath and Poledra (I had to look it up). Google says: Poledra, wife to Belgarath, mother of twins Polgara and Beldaran, ancestress of Belgarion. Poledra is called the "Woman Who Watches" in the Mrin Codex. Originally a wolf who learned to take human form after observing Belgarath

I've worked in small, medium, and large plan firms/markets, but each firm has had one or more ERISA attorneys on staff. So by actuary does all the work, do you mean the firm? Assuming yes, in the small firm and market, 85% #1 and 15% #2. In the medium and large, I'd say 60%#1, 35% #2 and 5% #3. In the large market, my experience is 20% #1, 75% #2 and 5% #3

Thanks for the responses. No disagreement, but the wording in the regulation could certainly be clearer caused, I think, by a focus on social security leveling options.

Plan has an AFTAP of 70% and is comprised of two components (1) a traditional benefit that does not have a lump sum option and (2) an account balance type benefit that has a lump sum. Assume a participant has a traditional benefit of $200,000 per year plus an account balance of $15,000. Participant elects an annuity from the traditional and a lump sum from the $15,000. Can the $15,000 be paid or is it restricted to $7,500 under Section 436?

Has anyone studied the impact of the 2018 mortality tables on a 2018 lump sum?

I've never heard of recouping payments that weren't suspended due to failure to issue a SOB notice. What I have heard, from an ERISA attorney, is an argument that once the first month has elapsed a late SOB notice is no longer valid, especially if this is what the plan requires. This is obviously is a question for an attorney, but in my experience: no SOB notice, no suspension.

Necessary is a strong word. Highly advisable yes to comply with tax reporting requirements including PS-58 costs.

fe·al·ty ˈfē(ə)ltē/ noun historical noun: fealty a feudal tenant's or vassal's sworn loyalty to a lord. "they owed fealty to the Earl rather than the King" formal acknowledgment of this. "a property for which she did fealty"

Agree. The plan factors don't rule because there is no plan ERF.

Thanks for your comments

I have a related situation. 50% Separate interest QDRO that was approved as qualified (David I agree with you) but it does not address what happens if the AP dies before benefits commence. Guess what, the AP died before benefits commenced. From the QDRO "The Alternate Payee's award is a separate interest payable for the duration of the AP's lifetime". Is there some law or regulation that says the AP's benefit reverts to the participant absent any other language?

I always wondered who tipped garbage collectors..... (I guess this is my contribution to the board for this week)

FWIW, there's no question in my mind that aggregation is required. Excerpts from Internal Revenue Manual 4.72.6.2.1.1 (08-09-2016) Employer IRC 415: Treat all employees of these entities as employed by a single employer per IRC 414(b),(c) and (m): All corporations which are members of a controlled group of corporations (per IRC 1563(a), as modified by IRC 1563(f)(5) and not considering IRC 1563(a)(4) and (e)(3)(C)). All employees of trades or businesses (whether or not incorporated) which are under common control. All employees of the members of an affiliated service group are treated as employed by a single employer. See Treas. Reg. 1.415(a)-1(f)(1) and (2). When applying IRC 414(b) and (c), replace the phrase "at least 80 percent" with "more than 50 percent" in IRC 1563(a)(1), except to determine whether two or more organizations are a brother-sister group of trades or businesses under common control (IRC 415(h) and Treas. Reg. 1.415(a)-1(f)(1)). 4.72.6.2.1.2 (08-09-2016) Plan A DB plan is any plan which is not a DC plan (IRC 414(j)). Under a DB plan, participants accrue a benefit each year under a formula that must be explicitly stated in the plan. See Treas. Reg. 1.401-1(b)(1)(i) and Treas. Reg. 1.401(a)-1(b)(1)(i) and (iii). When you apply IRC 415(b) limits, treat all DB plans (whether or not terminated) ever maintained by an employer (or a predecessor employer) as one DB plan (IRC 415(f) and Treas. Reg. 1.415(f)-1(a)(1)).

Great link GMK. I am amazed that neither the Mariners or the Expos/Nationals have ever been in the WS.