Our firm took over a floor offset DB plan a couple of months ago. The plan's formula provides 4.75% per YOS to the business owner, and 0.5% to each other participant. The benefit offset from the PS plan is limited to 0.5% of pay. The participants except the business owner receive a 6% contribution in the PS plan. The prior actuary was treating this as a uniform allocation, I assume because the participant account offset is limited to 0.5% of pay for all participants. Essentially, the PS account was bifurcated into the portion which provides 0.5% of pay, and the remaining portion. Does this fly for the uniformity requirement for 401a26?
A further question, does anybody know what requirements must be met to use a preapproved plan document for the PPA restatement for a floor offset plan? My document seems to allow this, but doesn't elaborate on what requirements the plan must meet to use.
