XRA for reporting liabs if > $50M UVB

[Guest HarveyC]

Under ERISA 4010, a PBGC filing is required for single-employer plans with aggregate (within control group) UVB of > $50M. With this filing the value of plan benefit liabilities must be disclosed, using methods and assumptions as outlined under ERISA 4044. 4044.55 through 4044.57 deal with the determination of the XRA (expected retirement age) for valuing deferred benefits.

4044.55 deals with the XRA when a participant must retire from his job to begin receiving an early retirement benefit. 4044.56 deals with the XRA when a participant need not retire from his job to begin receiving an early retirement benefit. This latter situation does not appear to make sense as in-service distributions are not permitted prior to normal retirement age.

Thoughts?

[MGB]

(See my reply under the same question.) Under the other reply, I assumed these calcs are for a terminating plan. In this case, the plan is not terminating, so that 4044.56 does not apply.

[Guest HarveyC]

Thanks very much for the clarification. I definitely was looking at this a little too closely. Guess there's something to be said about the forest and the trees. Thanks!