Lifetime Income Illustrations

Getting pushback from an advisor (CPA) on this, and while I'm always ready to consider that I'm wrong, I don't THINK I am on this. 

For a 1-person plan (sole prop, corp, whatever) the CPA is saying the lifetime income illustration is required. I say otherwise. SECURE amended ERISA 105(a) to add this requirement. ERISA 105(a)(1)(A) exempts the pension benefit statement requirement for one participant plans described in ERISA 101(i)(8)(B). The lifetime income disclosure under 105(a)(2)(B)(III)(iii) falls under 105(a)(2)(B) in general, which refers to statements required under clause (i) or (ii) of paragraph (1)(A) which as stated above, exempts the one-participant plans.

Am, I missing anything?

Agree with you 100%. The lifetime income illustration is a Title I requirement. Unless the CPA believes the plan is subject to Title I - in which case, bonding, disclosures, etc. all apply - then there is no requirement to provide the lifetime income illustration. That said, there is nothing saying you can't provide one, and if the CPA really wants to see it, I'm sure you'd be happy to prepare one for him, for a modest fee....

Thanks. In this case, modesty is inappropriate, so a FULL fee would seem indicated!

You are right.

Even more broadly than your reading of ERISA sections 101 and 105, nothing in part 1 or any part of subtitle B of title I of ERISA governs a plan if the plan is not ERISA-governed because the plan is not an employee-benefit plan within the meaning of ERISA § 3.

A nonapplication of ERISA’s title I does not, at least not by itself, preclude a plan’s administrator from generating an illustration; but that’s a choice, rather than a response to ERISA § 105’s command.