SSRA

[Guest quinn the car fixer]

is it ok to use this option? Does anyone know if corbel's doc defines the testing age as NRA--would that then preclude you from using it? if not written that way--is relius relying on 401(a)(5)(f)(i)?

Sal's book says get determination letter before using--has anyone done that?

thanks

[Tom Poje]

I have my leanings against using the SSRA option at this time.

I don't believe Corbel's document defines testing age, but it certainly could be done in one of their individually designed documents. which of course means you would hopefully apply for the determination letter.

Here is the answer I read way back a number of years (pre-Sal)

"I suspect a lot of people are simply using SSRA as testing age, despite the fact the document defines NRA as 65 and the regs require you to use NRA"

The other issue that arises, even if you define testing Age as SSRA is a possible BRF issue.

Are you then required to test age 65, 66 and age 67 separately for BRF. If you do, you will probably fail that, so SSRA becomes useless anyway.

No, never have bothered to try and get a document as such. with the gateway minimum requirement I don't know if it would be worth the extra involved.

By the way, I also have leanings against the rate banding. Currently the system will take an HCE and place them at the Hi point. The midpoint is then determined and the Lo Point as well. This is cleary a problem with the regs that says you can group accrual rates as long as the grouping doesn't overly favor the HCEs. You can massage things a little bit by setting your own bands, but...

Be careful out there just punching buttons!