Calculating Grouped EBARs

[Guest merlin]

The Corbel/Relius software uses the HCE EBAR as the upper bound of the range, then calculates the mid point and lower bound accordingly. Any body have a problem with this methodology?

[wmyer]

there have been a couple of prior posts on this topic. if i recall correctly, tom poje does have a problem with this methodology, and that's good enough for me.

[Tom Poje]

while I appreciate the comment, you shouldn't rely on my opinion - it is really the regs - see 1.401(a)(4)-3(d)(3)(ii)

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Accrual rates within a range may not be grouped under this paragraph if the accrual rateswithin the range genearlly are significantly higher than the accrual rates of the NHCEs in the range...

There are no guidlines what would be considered significantly higher, but you are very observant Merlin - setting the HCE at the top bound would seem to fail the smell test of this reg. good job, 10 points.

I know you can manually set the range(hint hint hint - I would do it that way), but I have only been able to do this for one HCE - I am not sure if the intention is to be able to set more than one range at a time, maybe I am doing something or wrong, or maybe there is glitch in the system