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Posted

Anything interesting come out of the meetings that anyone wants to share?

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

Posted

Obviously a heavy focus on PPA. This of course was muted by the fact that we are still in the stage of blind men trying to describe an elephant given the lack of actual guidance (or for that matter, interest rates) on the full implementation of PPA.

Some impressions though:

The one size fits all approach to min/max funding begs the question as to whether one can continue running current method valuations to develop a recommended contribution in the middle of what will be some substantially larger spreads in 412/404 costs than we and our clients are used to seeing. Pure minimum funding on an accrued benefit basis (only being able to recognize salary scale for the current year) will lead to some Eiger like curves in normal costs, especially for final average pay plans, so that is no panacea for clients to pursue. Thinking out of the box for ok funded plans there will be substantially more flexibility in contribution ranges than before. Again though, would be helpful to see those interest rates (and mortality tables) to start forecasting impact for clients.

Focus has been on the DC disclosure statement timing requirements, but what is eye-opening is the actuarial certification due 120 days after plan year beginning. Any bet on the odds of you having all of your over 100 life vals done 120 days into the new year (especially since contributions are now "live" for interest purposes after plan year end)?

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