PPA 06 Small Plan Unisex Mortality

[carrots]

Can small plans use unisex mortality under IRC 430(h)(3)? The regs, at 1.430(h)(3)-1(b)(2), only seem to allow small plans to use combined tables for annuitants and nonannuitants; the regs don't seem to say anything about combining the male and female tables. Although, in the Explanation of Provisions, the IRS states, "These regulations provide an option for smaller plans that choose to use static mortality tables to use a single table for all participants - in lieu of the separate tables for annuitants and nonannuitants - in order to simplify the actuarial valuation for these plans."

Clearly, the male and female tables are combined under 417(e)(3); but, what about 430(h)(3)?

[FAPInJax]

Small plans use the Optional Small Plan tables which are gender distinct. One option would be to fund for 100% lump sums which would then use the Applicable table which is gender neutral (being a 50/50 blend of the Optional Small Plan tables).