Termination of Frozen DB

[J. Bringhurst]

We will be filing for a favorable determination letter on the termination of a previously frozen DB plan. When completing the applicable forms (e.g., Form 5300, attachments, NIP), must everything be filled out as if the plan were not frozen? For example, Form 5300 requests information regarding the plan's eligibility provisions and benefit accrual formula. As of the freeze date, no new participants and no additional benefit accruals. Do you include the pre-freeze information or just leave blank with a note that the plan has been frozen?

[SoCalActuary]

You indicate when the plan was frozen, and you show zero accrual for all employees, assuming this was a "hard freeze".

Be prepared to justify the benefit accrual rates and non-discrimination results for the last plan year before the freeze occurred.

[J. Bringhurst]

Yes, just took another look at Form 5310 and realized that it doesn't require all the same information as Form 5300 (does not require benefit formula or vesting schedule).