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Showing results for tags '415 ls post age 70'.
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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?