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Posted

A cash balance plan has made in-service distributions to participants in the past. They are now amending actuarial equivalence. In addition, they are amending the plan's hypothetical contribution credits to bring certain participants to their maximum benefits under 415.

When considering the distributions previously made, are we allowed to revalue the benefit based on the new actuarial equivalence?

Also, when adjusting the payment from the age that it was paid to the present, should the adjustment be made using the interest crediting rate or the post retirement interest rate?

Posted

my procedure: Determine what % of the max 415(b) LS was paid out at the distribution date (using age, comp, and factors applicable to that date). That portion of the current 415(b) limit (applicable to today) is used up.

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