Sixpack

I have a case where the contribution to satisfy MRC in a pension plan was deposited in error to the clients profit sharing plan. We can't seem to agree on how to correct it. EPRSC doesn't seem to cover it. The MF deadline has passed (9-13-19) and the deposit was made timely but to the wrong plan. It seems the deposit to the PSP should be transferred directly to the pension plan and recorded as the MFC, but we don't see any guidance to support this approach. Alternatively to return the contribution to the corp then pay it over to the DB but then would it be considered late. If anyone has dealt with the problem, what is the proper correction?

Unclear on significance of SOBN requirements for a small plan covering only the business owner where future benefit accruals can still occur. Consider a unit benefit 10% x service formula, now has 7 yrs of service, now age 70. The AE of his prior benefit exceeds 70% comp limit, so can't accrue in current year. Forfeiture goes away in following year. Does the owner really have to give himself a notice?

I have an issue with a case involving 2 concurrent pension plans covering an employee who is 72 years old and has 6 years of service and 5 yrs participation ( at NRA). Both plans are being terminated in 2019. Plan A was started 1 year before plan B. Both have the NRA = 65 +5 participation. Plan A NRA for this employee is 69 1/2, Plan B it is 70 1/2. High3 is about $170,000 so the C Limit will apply. In order to compute the dollar amount and equalize the benefit and retirement ages, I actuarially adjusted the 69 1/2 benefit in plan A to age 70 1/2. Then computed the LS for both plans with the age 70 1/2 APR and the distributions were made earlier this year. I think I blew 415 since I actuarially increased the benefits before the LS payment and under C limit which doesn't adjust; not sure what to do to correct them. Have any of the actuaries faced this before? Key Questions--1) How do I avoid blowing the C limit if I have to compare both benefits as of the same age? 2) Also, since a forfeiture occurred by not paying out the LS at the NRA, do I have to produce a benefit notice? Is there a sample notice others have used?

David--The plan is " top heavy" but there are no other employees, so it has no impact as the docs state TH Min is only for non-key employees. I was hoping to find someone who has been doing this so I could compare notes. What do others do with the annual MRD distribution method? Is there a required distribution form that must be executed each year? I mean other that an initial disclosure that this method has been selected to satisfy the MRD. The regs under 401(a)(9) seem to be poorly written and difficult to follow, as least for me.

Owner only pension plan. NRA is 75 (65+5). MRD will be taken as an annual single sum payment equal to 12 x prior year monthly accrued benefit in December each year. With an EOY valuation, the actuarial equivalent of the MRD must reduce the accrued benefit used to compute FT under 430(d)-1(c)(1). Didn't use cliff vesting. Is there another way to do the MRD without a funding impact?

A client has a DB plan, started in 1998. The plan was subject to a Hard Freeze in 2016, and a new pension plan was established. The frozen plan is DB001, the new plan DB002. Both plans are overfunded with significant excess assets. DB001 accrued benefit is $12,000/mo, DB002 $1,500/mo. Both plans terminated in 2018, participant is now 70. The aggregate 415 limit is $14,166.67/month ( C limit) and the aggregate 415 LS (both plans) is $1,799,000. Note the accrued benefits in both plans is $13,500 < 415 limit. The question is how do I apply the 415 limit to each plan? The plan doc says to apply the 415 limit first to DB001. The problem comes from the MPV which impacts the 415 limit even though the total accrued benefits as annuities do not exceed 415. The PVAB ( MPV) is $1,700,00 in DB001 and $225,000 in DB002. It seems that DB001 pays the full PVAB and DB002 get the knife. This doesn't seem right. Is there another approach?