Relative value postponed for QPSA?

[Guest beckys]

It doesn't look to me like the delayed effective date applies to the QPSA changes? The announcement doesn't mention QPSA at all. And it says that 1.417(a)(3)-1 is delayed "with respect to QJSA". Does anyone have an opinion?

[MGB]

It is only some of the QJSA notices that are delayed.

The only reason for the delay is to allow companies to delete optional forms at retirement under the proposed 411(d)(6) regulations, prior to having to illustrate them under relative value regs. That can't be done until the proposed regs are finalized next year. That regulation has no effect on the QPSA notices, so there is no reason to delay them. Similarly, you cannot delete a lump sum option under the proposed regulations, so there was no need to delay their QJSA relative value disclosure, either.

[Guest HarveyC]

In terms of the QPSA notice, the relative value regs do not appear to apply to plans that fully subsidize the QPSA benefits; only plans that charge for QPSA coverage must comply with the relative value disclosure requirements. All the plans I deal with have fully subsidized QPSA benefits and so I'm ignoring the new disclosure requirements for the QPSA notices.