NRA - doc due today

[HarleyBabe]

Was given a last minute document to do and racing a little. I haven't had to prepare the docs before and have a question about the NRA. Their current doc had a retirement age of 58 and 10 on part but no later than 65 and 5 on part. Question is, how do I accomodate that first piece. I don't believe that is allowable any longer is it?

[Andy the Actuary]

58/10 is still allowable so long as you can support it reasonably representing the norm for the plan sponsor's industry. How to demonstrate this? Generally, good luck.

[HarleyBabe]

problem is, I"m coding the doc and 58 and 10 isn't an option. It warns me that it shouldn't be less than 62. Using an FT william Doc, How would I code the doc. I can add a custom sectio nthat won't throw it off their prototype. They, meaning FT Williams support, suggest putting an early retiement in.

[John Feldt ERPA CPC QPA]

Could you put in a fully subsidized early retirement benefit payable at 58 and 10? and change the NRA to 65/5? Will that fit the prototype? Will the actuary be satisfied with that solution?

[Andy the Actuary]

Will the actuary be satisfied with that solution?

Including this actuary's spouse, no one has ever voiced concern over an actuary's satisfaction.

If it fits the prototype, you could have NRA = 65 (or even 62) as a safe-harbor and then have unreduced e.r. at 58/10. This stuff was covered in IRS Notices 2007-8 and 2007-69.

[John Feldt ERPA CPC QPA]

Including this actuary's spouse, no one has ever voiced concern over an actuary's satisfaction.

Funny.

When an issue comes up, e.g. the Final NRA Regs interim amendment, the Final 436 Regs interim amendment, or even some individual plan amendmens, we prefer to discuss the issue with the actuary before writing the amendment. Other amendments, such as a plan freeze amendment, would certainly not need such discussion, although the actuary would have already been involved with answwering any impact questions re: funding, effect on financials, etc. If the amendment increases benefits, confirmation of the funded status takes place (if not already determined). FWIW.