DB offset plan and 415 limits

[Guest Dave Peckham]

I have a DB offset plan that is getting ready to terminate. It looks like there will be excess assets. I would like to do an amendment upon termination to allocate the excess assets. I know that the amendment must pass 401(a)(4) by itself. My question is on 415 limits. Say, for the owner, I take the DB accrued benefit prior to offset, subtract the offset amount, and arrive at $15,250 per month payable at age 62. Can I structure my amendment to provide $1,000 additional accrued benefit to total $16,250 per month at age 62? Or does my DB accrued benefit prior to offset and prior to amendment need to be limited to $16,250?

[SoCalActuary]

Your 415 limit is applied to the distribution amount and separately to the funding amount. Both are net after the offset. Allocate away.

[Guest Dave Peckham]

Wonderful. Thanks for the speedy reply!