Post NRA

[ombskid]

If a participant reaches normal retirement age and retires, takes a lump sum distribution, then decides to work part time (approx 10k annual in this case) would the employer be required to provide this employee with a top heavy minimum benefit for the part time work?

Does it matter if this person was a HCE when employed full time?

[david rigby]

Is the TH benefit cumulative?

Is the EE's accrued benefit (expressed as a LA) already over 20%?

(HCE not relevant to TH question. Check for Key employee status.)

[ombskid]

Is the TH benefit cumulative?

Is the EE's accrued benefit (expressed as a LA) already over 20%?

(HCE not relevant to TH question. Check for Key employee status.)

I'm not sure what you mean by cumulative; but the plan limits the top heavy benefit to 20%, so no additional benefits need to accrue to this person because he already had accrued considerably more that 20% of pay.

Thanks. Too much DC work lately had me forgetting the 20% accrued benefit as 2% x up to 10 years (that's probably what you meant by cumulative)