Dougsbpc Posted March 28, 2006 Posted March 28, 2006 Can a DB plan have different definitions of service for benefit accrual and 415 limit? For example, suppose a plan requires 1,000 hours for benefit accrual. A participant will have 9 1/4 years of participation at NRA. The dollar limit would be multiplied by 9/10ths. Could a plan be designed to credit a year of participation for 415 purposes on 1 hour of service? In this case there would be no dollar limitation reduction.
SoCalActuary Posted March 28, 2006 Posted March 28, 2006 Currently, you can have different rules. The proposed 415 regs would eliminate that.
Ron Snyder Posted March 30, 2006 Posted March 30, 2006 The proposed 415 Regs are not going to be effective until 2007 and will undergo several changes before becoming final. So you should be good with such amendment for 2006 at least.
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