ABPT - Appropriate Compensation

[LIBOR]

In determining the DB accrual rate for the ABPT do you divide by plan year comp or average comp ?

On pages 60 & 134 of Labombarde's 1991 book entitled " A Guide to Nondiscrimination .................." , he indicates either but the regs seems to say only average.

Does anyone have a cite that would support the use of plan year ??

[AndyH]

What is your measurement period? Look at 1.401(a)(4)-3(d) which says average comp must be used and then (e)-(2) (ii) which says that plan year comp may be substituted for average annual comp if the measurement period is the current plan year.

And 1.410(b)-5 (d)(5)(i) sends you to (a)(4)-3(d).

[LIBOR]

great ! thanks Andy !