Definition of Accrued Benefit

[ERISA25]

In regard to a cash balance plan, does anyone know whether the definitions of accrued benefit for purposes of testing under 401(a)(4) and backloading under 411 have to be the same?

[ERISA25]

Is the rate that is used for purposes of calculating future interest credits under 401(a)(4) part of a participant’s accrued benefit for purposes of Section 411(d)? In other words, if for purposes of Code Section 401(a)(4) you project future interest credits at 8%, is that 8% for future interest credits part of the accrued benefit that is protected by Section 411?

[ERISA25]

More to the point, are future interest credits part of the accrued benefit for purposes of 411? Any thoughts?

[SoCalActuary]

More to the point, are future interest credits part of the accrued benefit for purposes of 411? Any thoughts?

I believe that the courts are consistently interpreting that some interest credit must be continued until distribution occurs.

So is the IRS. The interest rate must be the one contained in the plan document. If this is variable, based on some market determined rate, then your benefit at NRD will fluctuate each year when expressed as an annuity form of payment.

To my knowledge, the monthly benefit is not a protected amount under 411. There are some people who cannot get their hands around this idea, and insist that the prior year annuity benefit must be protected. IMO, they are wrong.

[ERISA25]

Thank you for your response. I'm trying to wrap my head around all of these complicated rules. Do you know of any guidance issued on this. My issue is whether a plan is bound by its assumptions it used for purposes of Section 401(a)(4) accrual testing, particularly whether those assumptions - the interest rate used - is a protected benefit under 411.

[Mike Preston]

Definitely not.

[ERISA25]

Mike, Do you know of any published guidance discussing this issue?

[Mike Preston]

Other than the fact that 411(d)(6) and the regulations under 1.411(d)-4 make no mention whatsoever of a protected right being created, established or linked to via any 401(a)(4) demonstration? Not a thing.