Cash Balance Plan Uniformity Requirements

[Guest HarveyC]

It appears that a cash balance plan cannot provide different contribution rates for a select group (even if passes nondescrimination rules) due to uniformity requirements. It also appears that a new cash balance plan cannot arbitrarly grant past service credits to individuals (i.e., the opening account balance)...seems like must grant past service on a uniform basis or the opening balance must be from a DB conversion. Please let me know if I'm wrong on either or both ascertions.

[MGB]

You only have uniformity requirements if you want to pass (a)(4) based on the safe harbor. General testing can do anything.

What other uniformity requirements are you possibly refering to?

[Guest HarveyC]

Thanks for clarifying that. After scanning through the regs I would agree with you that the uniforminity requirements only relate to safe harbor testing.

I arrived at my earlier conclusion from the Defined Benefit Answer Book. Q 3:31 poses the question, "Can a cash balance plan provide for past-service credit?" It indicates that past-service credits may not be provided unless certain uniformity requirements are met. It does not indicate that this question relates only to conditions for safe harbor consideration.

I guess the good book is not perfect. Thanks.