Plan aggregation

[Guest HRD]

Is anyone familiar with the rules under PPA or 430 regarding multiple DB Plans maintained by the same employer. If one us under-funded and others are not, should the plans be aggregated for purposes of determining funding liabilities and limits on lump sum distributions?

[JanetM]

Disclaimer - I am not an actuary. Our company has 13 DB plans with funding rates that vary from 71% to 116%. Our actuaries have given us AFTAB certs for each plan based on funding levels for that plan alone. We are one large control group with two SLOBs if that makes any difference.

[tymesup]

Both 430 (funding) and 436 (limits) reference the plan, rather than the employer. Therefore, there is no aggregation for these purposes.

Let's hope we haven't given our friends in government any ideas for new code/regs.