Suspension of Benefits

[Randy Watson]

Can an employer adopt a plan amendment that expands the kinds of employment that would suspend benefit payments if a retiree would not permanently forfeit the amount of payments withheld during the suspension period?

I'm trying to figure out whether the Heinz decision would apply where there is no permanent withholding of the suspended amount.

[Everett Moreland]

This comment is made without much thought. My reaction is that, if what you propose is to pay the suspended amount in the future, that would violate 1.411(d)–3(a)(3).