Bri

That sounds off, the "X hours in Y months" provision is usually written as the employee's FIRST Y months of employment. Plan language would dictate, of course. Does the "498 in 6 months" have fallback language to make sure someone with 1000 hours in their 12 months gets swept in?

If it's a rollover, then no, since the participant's spouse would have had to waive already in order to get the lump sum out of the DB plan. Once that hurdle was passed, all bets are off.

The final SB is going to reflect the assets/measurement at some point in time before the payouts all took place, so if they happened to still have a PFB at the time, no big deal.

Do they WANT to do this as an end-run around the plan's loan provisions?

I'd agree, unless the plan termination is also tied to a company sale or something where the participants have severed employment.

Not disagreeing but I would want to see the document text more before fully concurring.

Also they'll get a partial credit towards the gateway from any CB pay credit. However, it almost definitely will not be one-for-one, but rather an "equivalent" allocation rate based on the DC testing parameters.

1.72(p)-1 and go from there maybe

Indeed, the loan 50% rule only applies when it's taken. People have been doing the "Borrow half, hardship the rest" move for years....and that clearly leaves the loan as 100% of the remaining balance.

A one month plan year is going to have a really small 415 limit. If you've got individual allocation groups, why not "rig" the amounts for both plan years to be the total they want to give out, and deposit the total on the 11/30 records?

The QJSA is what he'd get without any signature. If the guy wanted a single life annuity the spouse would still have to sign away her position.

Would need to see a little more, like why is there still any shortfall amortization if the assets exceeded the FT? Was there a PFB?

I think that the 5500 is based on 318 attribution, whereas PBGC coverage uses 1563 but requires spouses to be in a corporation (not just an LLC electing tax treatment). So maybe they're a little of each, an EZ with PBGC coverage? for )

We've used EBG's planning software, since it includes making sure the proposal passes all the tests. We just create a new "proposal" for each plan year.

Ha, as an actuary I'd not necessarily say it's prudent (absent facts and circumstances) but it's certainly typical