Normalization of benefits for nondiscrimination

[FAPInJax]

A plan has a non-uniform retirement age of 62. Therefore, the benefits must be normalized to 65. I understand that testing assumptions are used for the conversion so the ratio of the APRs is easy. However, is it an interest only or interest and mortality adjustment?? Does it depend on whether the definition of actuarial equivalence includes pre-retirement mortality??

[Tom Poje]

time out. if everyone has the same retirement age of 62, then the retirement age is uniform, it is simply not the usual 65 you commonly see. so testing age would be 62.

[Guest merlin]

OK, let's say anyone can retire with 30 years of service, regardless of age. Same question.

[Blinky the 3-eyed Fish]

A quick read of the definition of normalization or normalize or whatever it's called in (a)(4)-12 will mention that a standard mortality table is acceptable. That should answer your first question that there is a mortality adjustment along with interest. As to the question about whether or not the normalization is affected if the DB plan has pre-retirement mortality or not, I say it does matter.