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A participant in a cash balance plan continues to work past NRD. They continue to receive an allocation (theoretical) and earnings.

First, they must have their NRD benefit protected with actuarial increases, correct??

Now, the testing for nondiscrimination.

Is it proper to set the most valuable EBAR for this individual to the normal EBAR??

IF not, it would appear they would be subject to the same rules as everyone else - convert the increase in the accrued benefit (if using that particular method) from the normal form to a QJSA using actuarial equivalent and then convert back at testing assumptions. This would cause a different EBAR. Right??

Thanks for any and all help. The mind is a little frazzled and the regulations do not seem to reference what to do with people continuing to work after NRD.

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