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Posted

Do you think it is permissible in a Cash Balance Plan to only credit compensation as a participant (from date of entry) in the first year a participant joins the plan?

Generally this rule is only used for DC Plans and is not used for DBs, especially final average pay DBs. But since a Cash Balance Plan accumulation formula is commonly based on each year's pay, and since the 401a4 Regs clearly allow testing comp to be done this way, I believe it should pass muster.

Any thoughts?

Posted

I don't think it is a problem. I have a plan that does it, the IRS has reviewed it and issued a determ letter.

No different than any other career average unit credit formula - partial years are ok with them.

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.

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