reducing a 100% QPSA to a 50% QPSA

[Everett Moreland]

My research indicates that an employer may reduce a 100% QPSA to a 50% QPSA with respect to all service without violating 411(d)(6) or giving a 204(h) notice, because the QPSA is an ancillary benefit.

The reduction would apply to deaths occurring after the date of the amendment, to both active and vested terminated participants.

This is a fully subsidized mandatory QPSA (waiver not allowed) in a defined benefit plan.

This answer seems right but leaves me uncomfortable.

Do you agree or disagree with this answer or know of something I've missed?

[Guest Harry O]

Seems right to me (FWIW).