Age Methodology

[Pension RC]

I am working on a terminating DB plan. The plan is vague when it comes to age to 417(e) purposes. From what I've read, it appears that, if a certain age methodology was used for calculating lump sums (such as years and months) while the plan was active, then changing it to anything else to pay termination lump sums would be a 411(d)6 violation. Would you agree? Is there an argument to the contrary?

Thanks!!

[david rigby]

Consistency in administrative practices is a good practice.

If the proposed change would benefit NHCEs, that might be a good argument in favor of a change.

[Mike Preston]

Not a good one.