Cash-Balance Plans

[JAY21]

Last I checked on this if we used the various proposed reg options to credit theoretical accounts with an interest credit equal to actual rate of return on plan investments, you had to use that annual rate (not an average) in your DB/DC combo testing. Is that still the case or has there been anything new on this that would allow an "average" of multiple years' returns to be used instead of each year's ? Thanks.

[Grendel77]

sidestepping your question of whether the most recent return is required: what does the plan doc say? It will specify what rate(s) to use when projecting the hypothetical balance to NRD in order to determine the SLA under the plan. This is the normal ben provided by the plan, so it's what is used in testing to determine the EBAR.