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415(b)(1)(B) limits the benefit accrued to 100% of the high 3 years of compensation. Owing to actuarial increases, it's not unusual that the actuarially increased normal retirement benefit could exceed the 415(b)(1)(B) limit. In such case, it would appear this limit could conflict with 401(a)(9).

I have a take-over where this has occurred. The employee is 72 (with 51 years of service!), the AAC=$60,000, the NRB=35,000, the LRB=44,000, and the actuarially increased NRB=69,000.

To protect the employee against forfeiture, the Plan would need to incorporate a retroactive annuity start date.

Any thoughts?

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

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