415 Mortality

[abanky]

I'm pretty sure this is yes... but is the mortality table used to calculated the maximum 415 lump sums for 2008 plan years the same as the 2008 Applicable Mortality Table?

[flosfur]

I'm pretty sure this is yes... but is the mortality table used to calculated the maximum 415 lump sums for 2008 plan years the same as the 2008 Applicable Mortality Table?

It doesn't appear to be so. S415 mortality table is supposed to be based on the prevailing commissioners' standard table - this was not changed by PPA. The new S417 applicable mortality table under PPA is the mortality table prescribed under S430(h)(3)(A).

[tymesup]

Senate Bill 1974 provides that the 417e mortality table will be used for 415. Since there is no corresponding House bill, nothing will happen until Congress reconvenes. From the description:

B. Interest Rate Assumption for Determination of Lump Sum

Distributions

(Act sec. 302 and Code sec. 415(b)(2)(E))

The Act amended the interest and mortality table used in calculating the minimum value of certain optional forms of benefit, such as lump sums. The provision clarifies that the mortality table required to be used in calculating the minimum value of optional forms of benefit is also used in adjusting benefits and limits for purposes of applying the Code section 415 limitation on benefits that may be provided under a defined benefit plan.