Jump to content

Craig Jacobs

Registered
  • Posts

    9
  • Joined

  • Last visited

Recent Profile Visitors

The recent visitors block is disabled and is not being shown to other users.

  1. I may have missed it, but has the 417(e) applicable mortality table for 2024 lump sum distributions been published? Thanks!
  2. Does the recent IRS Notice 2020-23 apply to Annual Funding Notices? Would they be delayed to July 15th as well or still due April 30th? Thanks!
  3. Thanks Andy. I assumed estimation techniques would be ok and, in this particular situation, the impact on the AFTAP is not material (AFTAP is just over 100%, so doing the adjustment merely brings the AFTAP down slightly). However, had our AFTAP been under 80% and the adjustment gets the plan over 80%, I'd want to be more precise. For HCE/NHCE determination, would that be based on when they terminated employment? Or is the HCE/NHCE determination based on the year of the purchase. i.e., if a retiree terminated years ago, regardless of his compensation at termination, he would not be an HCE in the year of the annuity purchase. I got to think that there have been a number of retiree buyouts over the past couple years. Wonder how people are handling this. Thanks again!
  4. Under 436, both the AVA and the FT is to be adjusted by adding in the value of annuities purchased in the prior 2 years for NHCEs. If a plan purchased annuities for its entire retiree population, how would one determine NHCE vs. HCE, especially given that many retired more than 10 years ago? Since it was done as a single transaction with one purchase price, how would one be able to allocate the purchase price between NHCE vs. HCE? Thanks in advance.
  5. For those who believe the plan has until the following Monday to make the contribution, how do you get around Gray Book 1995-9? That seems to indicate the opposite.
  6. Isn't the notice to plan participants due sooner than the mailing of the AFN?
  7. Now that we have clear guidance from the PBGC that we cannot use MAP 21 rates for the alternative method. I was wondering about PBGC 4010 filings. For determining either the 80% FTAP or the $15,000,000 shortfall, can MAP 21 stabilized rates be used?
  8. For a traditional annuity plans that pays lump sums under 417(3), the regs had indicated that the lump sum conversion basis in your valuation should equal the funding segment rates. So for a 1/1/2012 valuation using a September lookback, the lump sum conversion basis and the funding segment rates are both set to be equal to 2.06% 5.25% 6.32%. Does that still apply under MAP 21. So for a 1/1/2012 valuation for a sponsor that elects to take advantage of MAP 21, would the lump sum conversion basis be 5.54% 6.85% 7.52% (same as the 2012 funding segement rates)? If not, then MAP 21 would not have a significant impact for a plan that pays 100% lump sums at decrement. Obviously none of this would impact the actual amount of benefits paid since those would still be determined under 417(e). Thanks
×
×
  • Create New...