415 lump sum limit and several plans

[abanky]

Comp 245,000

Date of hire was centuries ago.

I've got a participant in a frozen DB plan with an annual benefit of 100,000. The same participant is also in a New Multiple Employer plan (Same ER in both). The participant has an benefit of 95,000 in that plan.

The participant's combined 415 annual benefit is not violating anything... however, when I calculated the lump sum in the old plan and add it to the lump sum of the new plan, I'm above the 415 lump sum limit. Individually, i'm not.

Is the 415 lump sum limit plan specific? or combined like the dollar and comp limits?

[David MacLennan]

The two plans must be aggregated and treated as one plan for 415. You might have some plan document issues if they were not carefully drafted, and usually they are not.

[abanky]

Thanks David, I see that now.