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Posted

Hi,

We have a plan that failed to put retirees in pay status for the past 3 years.  The plan provides that the lump sum benefits will be calculated using the interest rate as of November preceding the plan year in which the distribution is made.

Which interest rate do I use when calculating the missed payments? Do I use 2016 for all plan years (2014, 2015, 2016) since the payment will be made in 2017?  or do I need to use the Nov 2013 interest for 2014 payment calculation,  Nov 2014 for the 2015 payment and so forth?

Thank you.

 

Posted

There might be some corollary issues to address first.

What is the nature of "...failed to put retirees in pay status..."?  Do these retirees know something is missing?  Should the PA be discussing fiduciary liability with its ERISA attorney?

Why a lump sum rate?  Are you trying to identify how to make up for overlooked annuity payments?  Is there an administrative precedent?  What does the plan say about RASD?

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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