417(e) Question

[ERISA25]

In regard to a cash balanced db plan, is IRC Section 417(e)(3)(B) (Applicable mortality table) and © (Applicable Interest Rate) a floor against which the accrued benefit is measured? In other words, the present value of the accrued benefit can be more than the present value calculated by using the applicable mortality table and the applicable interest rate.

[John Feldt ERPA CPC QPA]

If the cash balance plan meets the requirements of PPA and subsequent guidance to be eligible for 417(e) avoidance, then the cash balance portion of the plan is not subject to 417(e) - no more whipsaw issues there, the lump-sum benefit payable is equal to the hypothetical account.

However, if the plan is top heavy and if the top heavy minimum is earned in that plan, then the top heavy minimum benefit is subject to 417(e) and its lump-sum value will gyrate up and down with changes in interest rates like a traditional DB plan. The lump-sum value of the TH minimum is compared to the account balance at the time payout occurs.

Also, if a portion of the plan contains a traditional formula, either as an old preserved benefit or as an ongoing formula, and if that benefit is subject to 417, then that portion of the overall plan benefit would need to be calculated using 417(e) rates.

[david rigby]

... is IRC Section 417(e)(3)(B) (Applicable mortality table) and © (Applicable Interest Rate) a floor against which the accrued benefit is measured?

Just to be clear, 417(e) is not about "accrued benefit", but about the lump sum present value of the accrued benefit.

[ERISA25]

... is IRC Section 417(e)(3)(B) (Applicable mortality table) and © (Applicable Interest Rate) a floor against which the accrued benefit is measured?

Just to be clear, 417(e) is not about "accrued benefit", but about the lump sum present value of the accrued benefit.

Am I correct, that a participant’s benefit is the greater of the PV of the Accr. Ben. under the Plan’s rate and such benefit calculated using the applicable interest rate in (d)(3) and the applicable mortality table in (d)(2). In other words the rate provided in 417(e) is a floor.

[david rigby]

In other words the rate provided in 417(e) is a floor.

The present value under 417(e) is a floor.

[John Feldt ERPA CPC QPA]

However, just to be clear, you will not need to project the cash balance account at the hypothetical rate, convert to an annuity, and then discount back at the 417(e) rates in order to determine the lump-sum value of the hypothetical account (as long as the PPA conditions are met).