Kent Allard Posted December 19, 2023 Posted December 19, 2023 The freezing of a defined benefit plan perforce seems to affect the tallying of accrual service, and perhaps also the reckoning of the remuneration of which the accrued benefit serves as a function. Perhaps conversely, freezing the plan might not affect the reckoning of the high three year remuneration streak for § 415(b) deliberations. Please provide helpful guidance on this situation. Also, the reckoning of years of service and/or years of participation might remain unaffected. If guidance has resolved this situation, please provide in a reply.
CuseFan Posted December 20, 2023 Posted December 20, 2023 3-year average compensation may be taken from any consecutive period, pre-plan, post-freeze. Likewise for Years of Service. Participation is credited service for which the person accrues (or would otherwise accrue) a benefit - so no for pre-plan and no for post-freeze. See the regulations. C. B. Zeller 1 Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
Kent Allard Posted December 20, 2023 Author Posted December 20, 2023 Please helpfully provide citations, if helpful.
Luke Bailey Posted December 27, 2023 Posted December 27, 2023 Kent Allard, in addition to what CuseFan has stated above, I would point out that most employers that freeze their DB plans do so to lower cost/limit risk. So they choose to freeze everything, including comp for benefits and 415(b). Luke Bailey Senior Counsel Clark Hill PLC 214-651-4572 (O) | LBailey@clarkhill.com 2600 Dallas Parkway Suite 600 Frisco, TX 75034
david rigby Posted December 27, 2023 Posted December 27, 2023 @Luke Bailey is correct. In my 40+ years as a pension actuary, I've never seen a plan that was "frozen" except for comp. 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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