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Posted

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.

 

Posted

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.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

Posted

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

Posted

@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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