I have a related problem for a multiemployer Money Purchase Pension Plan (MPPP) that has individual participant accounts.
My understanding is that due to the definitely determinable benefit rule (26 CFR 1.401-1(b)(1)(i)), a MPPP may not refuse to credit a participant's account in the event of employer delinquencies. However, since this MPPP has individual accounts, where does the money come from?
The IRS has already told us we cannot divert a percentage into a reserve account for delinquencies (because all the funds must be used solely on behalf of the participants -- at least that was their justification for refusal). Can we pay the shortfall out of the Administrative Fund? If not, are there other ways of getting the money into the participants accounts?
