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Guest allen293
Posted

"A plan may provide that the benefit accrual required under [411(b)]" is reduced (but not below zero) by the amount of any actuarial adjustment under the plan in the benefit payable for the plan year with respect to the participant because of a delay in the payment of plan benefits after the particpant's attainment of normal retirement age."

This comes fom proposed reg 1.411(b)-2(b)(4), regarding adjustments for delayed retirements. This is also phrased as "offsetting actuarial increases against benefit accruals" earned after NRA. This language is probably cake to actuaries and many other plan professionals, but it has me baffled.

In one of the examples, a participant's monthly benefit at NRA with 30 years is $600. Participant works for one more year post NRA. His benefit would be $620 with the additional year of accrual. However, because the Plan has elected the above language, the Plan is "not required" to provide the extra accrual; instead it may provide the actuarially increased benefit of $672, which is the actuarial adjustment from the NRA benefit, based on delayed retirement. (This is from Example 2 of the reg)

I don't understand how this is a "reduction" or "offset." To me, reduction or offset involves subtraction. One variable is reduced by another variable. Rather, this is a matter of providing the greater of A or B, but not both. Is this simply a matter of industry terminology? What's even more confusing is that another example (example 6) does involve "offset" in my understanding (subtracting annual benefits from NRA benefits with additional accruals).

Can someone shed some light on this for me? Thank you very much.

Guest allen293
Posted

You can disregard (unless you're bored and want to burn up your keyboard).

Someone explained the "offset" that seems to make sense, though in my opinion, the examples in the regs don't illustrate this very well.

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