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Posted

how is one allowed to calculate whether a plan provides a meaningful benefit?

looking at a cash balance plan that uses the GATT rate in the calculation to avoid the whipshaw effect at payout time.

when determining if participants receive at least .5% does one also use the same assumptions (e.g. the GAR mortality at the GATT interest) or is one allowed to use any standard mortality table and interest rate?

Posted

I don't have Paul Shultz' memo handy, but IIRC it dealt with the provision of benefits, not the measure of benefits against a theoretical threshold for purposes of, say, non-discrimination. Hence, I would go with GATT unless I was shown something that indicated the more lenient calculations would be acceptable.

Posted

I agree with Mike. It's not a testing issue, its a benefit issue. Your Plan doc should contain process to convert the hypothetical cash balance account to a monthly benefit, generally this will use GATT assumptions. Once you determine the value of the hypothetical cb account, you can check it against Paul Shultz's .5% minimum.

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

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