415 limit for frozen fiscal plan

[Jakyasar]

Having a slow brain day for a change.

Fiscal plan 5/1/22 to 4/30/23. 

Limitation year is plan year.

2022 415 limit 245k, 2023 415 limit 265k

Froze the plan 5/1/22.

What is the frozen 415 limit?

[CuseFan]

Isn't it the limit in effect on the first day of the PY, so $245k? I see no way for it to be $265k, but may be the 2021 limit (probably not unless freeze was at 4/30/2022).

[Jakyasar]

Plan freeze is on 5/1/22 so at least the 2022 dollar limit. Need to have the 2023 limit though but still not sure

[Lou S.]

If it is frozen 5/1/22 I don't see how you get an accrued or projected benefit payable higher than the 2022 limit.

Unless maybe you have increased benefit for late retirement in which case I think your 415b limit is still the 415b limit in the year with your annuity starting date I believe.

[Jakyasar]

No late retirement.

 

[Effen]

Just unfreeze it, grant a small accrual, the re-freeze it.  Would need to be careful about discrimination if there are NHCEs not getting a comparable increase in their accrued benefit.  I believe the 415 increase is considered a new accrual that would need to be tested.

[Jakyasar]

Good idea but not an option. so looks like stuck with 2022 415 limit, right?