Final 415 Regs - applying the 401(a)(17) limit

[John Feldt ERPA CPC QPA]

http://benefitslink.com/taxregs/td9319.pdf

Looks like the final regs will keep the 401(a)(17) comp limit as an extra limit for 415 as well. This will limit the maximum accrued benefits for older employees so the actuarial increase in the 415(b) limit (post age 65) is also capped at the high 3-year average of the 401(a)(17) comp limit.

It allows a grandfathering of accrued benefits earned under plan provisions in place before April 5, 2007.

Anyone else looked at this yet? Agree? How do you perceive the grandfather provision working?

ak2ary - when do you anticipate being able to present on this topic?