Age to Normalize Benefits

[Dougsbpc]

Is it possible to use an age other than the NRA or SSRA to normalize benefits when cross-testing? For example, suppose you are cross-testing a DB and DC plan. Could you use age 70?, 75?

Also, is it possible to limit post-NRA APRs to age 65?

Thanks.

[Tom Poje]

you should be following

the latest rage

of what is required

of testing age

so whether you drink

coffee or beer

I think the answer

is pretty clear

so follow along

of that I beg

this can be found

it's in the reg

[1.401(a)(4)-12]

Testing age. With respect to an employee, testing age means the age determined for the employee under the following rules:

(1) If the plan provides the same uniform normal retirement age for all employees, the employee's testing age is the employee's normal retirement age under the plan.

(2) If a plan provides different uniform normal retirement ages for different employees or different groups of employees, the employee's testing age is the employee's latest normal retirement age under any uniform normal retirement age under the plan, regardless of whether that particular uniform normal retirement age actually applies to the employee under the plan.

(3) If the plan does not provide a uniform normal retirement age, the employee's testing age is 65.

(4) If an employee is beyond the testing age otherwise determined for the employee under paragraphs (1) through (3) of this definition, the employee's testing age is the employee's current age. The rule in the preceding sentence does not apply in the case of a defined benefit plan that fails to satisfy the requirements of §1.401(a)(4)–3(f)(3)(i) (permitting certain increases in benefits that commence after normal retirement age to be disregarded).

[AndyH]

But if you got two NRA's

Does that make this wrong?

Just repost here

And (maybe) Tom'll give you another song.