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The flat benefit formula using the fractional accrual rule--the question I am having is when is the 415  comp limit first applied. Is it to the projected benefit first, or  to the accrued benefit. We have  a plan document where it is not specified.  My interpretation has been that without specific language in the plan as to when it is applied, it seems it should be applied to the projected  benefit first since we can't accrue a fractional benefit to something that exceeds 415. In this plan the normal retirement benefit is 300% of average comp for 25 yrs of service at NRA.  Consider an employee who is 40 yrs old, NRA 65 and has $300,000 average salary. 

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