Andy the Actuary Posted March 30, 2010 Posted March 30, 2010 Assume Plan that covers about 150 participants provides lump sum as greater of PPA and 71GA/PBGC. A former HCE is age 60 and can retire at age 62 with unreduced benefit. As of 1/1/2009, AFTAP was 73%, which included assumption (right or wrong) that employee would elect lump sum at age 62. Given the near zero probability that the Plan will be 110% funded in two years, the HCEs benefit will likely be distributed in an annuity form. Question: Should the FT be valued assuming a lump sum will be paid or should it more realistically assume a monthly annuity form of distribution? The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
Effen Posted March 30, 2010 Posted March 30, 2010 I voted deferred lump sum because you said you were assuming the lump sum would be paid. I think you could change that assumption to something that better fit your situation. I don't think you are required to assume a lump sum payment anytime one is available. "1.430(d)-1(f)(4)(ii)(A) The probability that future benefit payments under the plan will be made in the form of any optional form of benefit provided under the plan (including single-sum distributions), determined on the basis of the plan's experience and other related assumptions" The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
SoCalActuary Posted March 30, 2010 Posted March 30, 2010 It seems reasonable to assume that the HCEs will get annuities while all others get lump sums. A 73% AFTAP has a reasonable chance to get 80%. Unless the client really pushes up their contribution, it is not reasonable to assume 110% will occur within the next 2 years.
david rigby Posted March 30, 2010 Posted March 30, 2010 IMHO, this is a good example of a need to change an assumption, no longer assuming that an HCE will get a lump sum. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
rcline46 Posted March 30, 2010 Posted March 30, 2010 My opinion is that the HCE will elect a lump sum. The plan cannot pay and therefore will annuitize until a lump sum is available, and then pay the lump sum. Some may think this requires a document change, I think the HCE restriction language specifically permits this. There fore I voted for lump sum.
Mike Preston Posted March 30, 2010 Posted March 30, 2010 Do whatever you would do had there not been a potential restriction. That is, ignore the potential of a 436/401(a)(4) restriction when determining assumptions.
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