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Guest AlCal
Posted

If benefit at NRA is a flat % of compensation(i.e. 100%) are we oblige to reduce it by at least 1/25 for each year of service less than 25?

Thanks

Posted

If you are referring to the safe harbor requirements of IRC 1.401(a)(4) with regard to the amounts of benefits, there is a safe harbor for flat benefit formulas which requires the 25 year reduction you mention.

However, a qualified DB plan can use any formula which will satisfy the non-discrimination rules. You can use the flat benefit formula without reduction, but you will have to use either the non-design based safe harbor which requires limited testing or the general test which requires full testing.

Posted

Also, if you are trying to create a benefit of 100% of comp, refer to IRC 415(B)(3) for the defintion of comp, and

refer to IRC 414(B)(5)(B) for the "phase-in", that is, the 100% applies where the employee has at least 10 years of service.

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.

Guest AlCal
Posted

Thanks for the input. More specifically; for a one person Standardized Prototype DB (no other participants)should I ever worry about this benefit limitation?

Posted

In your case it appears that the 25 year issue is not relevant. The only apparent and certain concern is 415.

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