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Posted

Have not done one of these in the last 3 years. Any new developments, regs, etc ?

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

Posted

Don't know of any new developments but would like to get your thoughts (funding only ) - the funding method is FIL - on the following approach to this situation :

I have a new client that opened (per plan amendment) & closed a window during the 1st quarter of 2004; I've opted per RR 77-2 to reflect the window on the FSA in 2005 rather than 2004; 20 participants take the window offering and all take lump sums.

I propose to establish the 30 year amendment ( window) base as the difference between the total lump sum payout and the EAN-AL as of 1/1/2005 for the 20 participants under the plan provisions prior to the window.

Does anyone see a problem with this approach or has anyone used a different approach for the situation where 77-2 is used in the following year as described above ??

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