hollywood

I have a (small) client with a couple of retirees that are interested in the new lump sum window that the IRS has recently started allowing for participants who are already in receipt. One of these retirees was a High 25 and was not allowed to select a lump sum when he retired originally. The client is also making steps towards terminating the plan. If they were not terminating, the plan would need to fund up so that they were 110% funded for this High 25 retiree to receive his lump sum. Since they are terminating, does that 110% still apply or does it go away? Logically it doesn't seem to make sense and it seems like they should only fund to pay out the benefits for the plan termination, but logic and the regs don't always agree. Does timing matter? We can't terminate the plan and then create a window to pay out the lump sums. If we create a window for the lump sums, then does the 110% apply since we haven't yet terminated. If we can't do it before or after, how can we do it "at the same time" - feels slightly impossible? thank you for any insight!

thanks - that makes sense!

Thanks. Our question comes down to whether the actuarial increase should be based on the spouse's lifetime or the participant's lifetime. We just cannot find anything to clarify in regulations etc. and the plan document is silent.

We have a plan that has not been able to locate the surviving spouse of a deceased TV participant for a number of years. The TV participant would have turned 65 in 2015 (when QPSA payments would have started) and we are wanting to begin distribution of the QPSA for the spouse soon. The plan does not allow for retroactive payments. Would the QPSA benefit due to the spouse be actuarially increased to 2017 based on the participant lifetime or the spousal lifetime? I cannot find any literature that handles this issue. Has anyone come across this? thank you