Suspension of benefits notification

[Gary]

A person worked until age 65 1/12. Is the Plan required to provide suspension of benefits notice in this situation (so close to age 65)?

The plan did not provide for an actuarial increase of benefit and the person's accd ben did not increase after age 65.

[david rigby]

According to proposed reg. 1.411(B)-2(B)(4), no qualified plan is required to provide the suspension of benefits notice. If it is not provided, and if payments do not begin at NR, then the actual benefit at "late commencement date" must be the greater of

(a) the benefit earned under the plan as of the actual severance of employment, including service earned after, or

(B) the actuarial equivalent of the normal retirement benefit.

Note that the reg uses NRA, note NRD.

Admittedly this is a proposed reg. issued in April 1988, but all documents I have seen since have incorporated this.