Hojo

Definitely no. The benefits are still determinable based on a set formula no matter if there are excess assets or not.

Niece.

Niece.

I think the original idea was that this was supposed to be addressed in the funding policy of the plan. Of course, it rarely is since the funding policy is generally written as a generic sentance saying that they intend to fund the minimum plus a discretionary additional amount to maintain the funded status of the plan. More government fun!!! We didn't fund for years and now that we actually have to fund those amounts it's too much...well ok, we'll just use falsely high interest rates to help you fund. Oh, and government plans aren't subject to the same rules as everyone else.....ugh.

How does the plan define years of service? Is it based on hours, elapsed time?

I think step one is to contact the Plan Sponsor of the 403(b) and ask for a copy of the spousal consent form. It's not the banks responsibility or the IRA's, but the 403(b) Plan's. If you are the confirmed spouse when she terminated, they have to give it to you. If they won't return your phone calls, go to their office.

MAP-21 is the funding basis so you are not underfunded by more than $50 million. Don't try to make it more difficult than it needs to be.

So the easy answer is yes, 60.04 > 60

Disability benefits themselves are not subject to 411(d)(6), but not sure in regards to impact on vesting and accruals......

The accrued benefit at Age 65 is dependent on 417(e) factors so it can still fluctuate. I think you simply need to put the caveat in Benefit Committment Form that the amount of the benefit may be different due to the timing of the payment, gain or loss in the plan's assets or a change in government mandated interest rates. Just CYA and you'll be ok.

I agree....it's stupid, but I agree.

Have you ever heard of Google? There are 500 calculators free on the internet. https://www.pensionbenefits.com/calculators/cal_main.jsp?sub_item=aecal

The 110% is based on the full value of the benefit. The bifurcation technically happens after the benefit is elected.

There's definitely a lot that you're misunderstanding here...You need to sit down with an actuary to understand how the 3% rule works, how your plan works, how early retirement factors work, what an accrued benefit means.....lots of things. I suggest waiting to talk with the PAL until you proceed with anything.

I'd be very interested to see how this doesn't pass the 3% rule.....

If the plans AFTAP has been certified for the year above 80%, then yes, you can pay out the whole lump sum.

I'm fairly certian that MAP-21 doesn't address 404 at all and therefore the max calculations haven't changed (ie, you use pre MAP-21 rates).

^This. If the plan is qualified and passes nondiscrimination testing, then as long as the plan is being administered properly they are not doing anything unfair. Now, whether you believe the background plan design is discriminatory is a matter that could be eventually taken up, but that is an entirely different case.

The Towers estimated rates of 4.72%, 6.09% and 6.78% weren't too far off from the actual of 4.94%, 6.15% and 6.76%. Impressive.

Anyone hear anything new through the grapevine?

I have rarely seen any pension consulting firm make a contribution recommendation for a sole proprietor without looking at the implications of 415 limitations and overfunding issues in the future years. Yes, I would ask for 2nd and even 3rd opinions, of course I would also expect you to pay another consultant for those opinions. People on this board are extremely helpful when it comes to issues that should be considered and what you should ask your pension consulatant so that you can have all of the facts. As the facts stand, your plan is overfunded on a cash basis. You may already be running into a 415 limit issue. Provide your actuary with an estimate of your future income and ask them to prepare an expected contribution stream through 2020. Talk with them about how they expect to project the Interest Rate assumptions (since we don't even know 2013 rates yet). Ask them to show you a range of expectations and work with them from there.

I have two questions along the same vein: 1) If the plan defines preretirement act equiv as 6% no mortality and post-retirement as 5% with some table with NRD age 65, actual retirement at age 66, how would you define the increase? I've got arguments for APR65 (5% with mort) x 1.06/APR66 (5%with mort) and APR65 (5% with mort) x 1.05/APR66 (5%with mort). 2) If the plan defines the late retirement actuarial increase as occurring at the end of every plan year and someone is retiring mid-plan year after NRD, do you still have to apply the act equiv at the actual ret date or only the increased benefit to the end of the prior plan year? (IE do the regs specify enough to overrule the plan?)

Yes, this is pretty standard. The QJSA is always considered the most valuable because, if not, then the QJSA fails 401(a). 417(e) just threw a screw into things, but I'm almost positive the IRS took the position that the QJSA trumps it in terms of testing.

Yes, that is what I am saying you "should" do, otherwise you might need a SOB notice as you might be decreasing the Acc Ben. Well, I never really thought about it, but I guess IF you issued a SOB notice you could get away with only looking at the AB at NRD. However, if you don't issue a SOB notice, then I think you must look at every point after NRD to make sure the AE of that AB, at LRD isn't greater than the AE of the NRD AB at LRD. In other words, you can't just look at it at NRD and LRD. You need to check the AB at all points in time in between. From a practical matter, for a longer service person, with modest accruals, the AE of the NRD AB will most likely be the greatest, however, if they have a large accrual in one year due to a high pay or a benefit increase, you could find the AE of an AB from a later date is higher. I agree with Effen here. That is how I was always taught to calculate the AE of the NRD benefit for all calculations. It doesn't generally happen that an accrual is greater than the AE one year and not the next or vice versa, but it definitely can happen and have seen it on a few occassions.

Don't know how it works in FT Williams exactly, but there are two ways around this in ASC that you may be able to similarly use. Option 1 - Enter your email address instead of your clients. Once you submit the form, you will get the email asking your to electronically sign the form. Either forward that email to your client, or write up a better email with directions for your client incl;uding the secure link. When the client electronically signs, you will get the confirmation and can pass that on to your client as well and thanking them for another successful/painful year. Option 2 - If there's room for more than one email address (seperated by commas for example), enter your email address as well. This way, when its signed you will also get the email confirmation. (not sure if that's available on FT).