Blinky the 3-eyed Fish

That is correct if the interest credit is based on a variable rate.

You better have a document that agrees and a determination letter to take the second approach. The first approach is probably what your document says. I am assuming you are contributing an amount to make the plan whole. Go forth and smite those second opinionites.

For 2007 you were allowed to use the 12/31/06 information to determine the AFTAP for 2007. By "use the 2007 rules" I mean using the 12/31/2007 information in a similar manner to determine the 2008 AFTAP. Now go take the poll one and all.

Feel free to add any comments.

Still 94 GAR. I don't know if the different technical corrections bills in both the House and Senate make the change.

Changing the NRA from 55 to 62 to under the guise that 55 is not reasonable is not a 411(d)(6) cutback. It just boils down to whether or not 55 is not reasonable. I am making that change when NRA is at least 55 for very few of my clients.

How will this allow for him to receive a payout in excess of the 415 limit? Andy, are you sure the age 55 NRA needs to be changed? After all the burden is to show it's not reasonable at age 55.

Not the case at all.

Unless you are going to allocate the contribution in the DC plan under an integrated formula or a pro rata formula and offset the DB with the entire amount, heed Effen's advice. It's easy and allowable to only offset using PS contributons from the effective date of the DB plan as ATA said. No problem with a BOY val and EOY PS allocations. The PS contribution and account balance growth is simply an assumption as part of the val. Of course you need to run EOY nondiscrimination testing using actual results.

The notice is required when the plan becomes subject to a restriction. In your example once the AFTAP is deemed to be 73%, a restriction applies and a notice must be given.

This is a non-issue. Everyone knows that jockeys have a pot of gold at the end of the rainbow. $15,000 is chump change.

They are participants for the 5500 count. When the benefits were frozen, plan entry should have been frozen too.

Seems to me like the participant can direct you (in writing) to have the money send to whomever and wherever they choose. They could direct you to take the check, pour salt on it and eat it for dessert , if you are willing to do it. As mentioned in other posts, the 1099-R is going to the participant, so there is no assignment of the funds. So get it in writing and if it's not a big deal, send the check as the participant wishes. Andy, I am glad your neighborhood is famous.

I agree with this 100%. Anyone know if they are coming out with anything else? This is no good to me at all.

I don't know. It's close. He definitely has Amy beat.

It has the attention of Elton John?

I don't think it's ignorance at all because the rules are less than clear. I believe your quoted paragraph states the methodology when benefits are not at a 415 lump sum limit. I base my opinion on this paragraph below just a little further along in the prop. regs., also on separate presentations I have attended and discussions with other actuaries. In the case of a distribution that is subject to section 417(e)(3) but that is determined as the greater of the benefit determined using the applicable interest rate and the applicable mortality table under section 417(e)(3) and the benefit determined using some basis other than the section 417(e)(3) assumptions, the proposed regulations would provide that the computation of present value must take into account the extent to which the present value of the distribution is greater than the present value determined using the applicable interest rate and applicable mortality table. So for example, if the AE lump sum benefit is greater than what's determined under under the paragraph you quoted, that AE lump sum would be considered and discounted at the appropriate segment rate (singular rate). It follows from logic then that a benefit at a lump sum limit would be treated the same way. My two cents.

Because I am assuming a lump sum and I don't believe that is the proper way to do it.

The same rules apply to CB plans as do to traditional DB plans.

I agree with Andy's take on this. I don't see RR 2003-65 on point to this problem as described above. I also don't see a new plan as an unfreeze of the first plan as Sieve suggested, being they are two separate plans. I doubt Andy cares about whether or not this is a good PR move. Remember it's an exam question that he got wrong, not a real-life situation. What happened to Effen's post? I guess he changed his mind?

The former. I bet some person who wrote that question is on these boards if you posted the year it was on the exam and the what exam it was from. You can do it! Be the ball Danny!

I would have received 0 points for my answer. I know of no "weird" rules that would make a partial termination equal to a termination for the predecessor plan rules. On a side note, are you studying to be an EA?

I disagree with the last post. You can remove someone from participation if they have been there more than 1 year. You can remove everyone except those named Steve if you like. Barring an ADEA violation or one that is a pseudo age/service violation, you can do about anything you want. Of course the applicable coverage and nondiscrimination tests must be passed. Oops Sieve snuck in, replace last post with last last post.

The answer is yes. I am too lazy to find you a cite.

I remember in English class to be very careful using words like must and always, etc. The balance could be under $5k, which would not require spousal consent.