Penman2006 Posted November 21, 2007 Posted November 21, 2007 I have a couple of calendar year plans with a NRA less than 62, but not less than 55. Based on reading Notice 2007-62 it looks like I can safely continue to use that NRA for the 2007 and 2008 valuations. Is that correct?
JAY21 Posted November 21, 2007 Posted November 21, 2007 Don't you just have "deference" on the issue, not a blanket safe-harbor ?
Andy the Actuary Posted November 21, 2007 Posted November 21, 2007 Take a look at the notice. It may be that you could have an NRD 65 but an earlier ERD. If so, case closed. 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.
Penman2006 Posted November 21, 2007 Author Posted November 21, 2007 Both of the reponses have me puzzled. Deference? Case closed?
Penman2006 Posted November 23, 2007 Author Posted November 23, 2007 Andy the Actuary are you saying to amend the plan to a NRA of 62+ and put in an unreduced ERB of say 55 and for valuation purposes assume everyone leaves at ERA? But my question remains, are changes to the NRA required (or advised) before 2009? What are others doing with their plans that have 55 >= NRA < 62?
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