Bucklaw20 Posted January 16, 2024 Posted January 16, 2024 Can a DB plan be amended to permit in-service lump sum distributions and also cease future accruals for any person who elects to take a lump sum?
Effen Posted January 16, 2024 Posted January 16, 2024 If the late retirement provision use the greater of the actuarial increase or the age/service benefit, the actuarial increase will almost always be higher. Therefore, if the participant receives a lump sum, and the plan offsets future accruals by the actuarial value of prior distributions, there will almost always be no future accruals. IOW, the value of the prior distribution will exceed the value of the additional age/service accruals and no new benefits will be payable. Luke Bailey 1 The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
Bucklaw20 Posted January 16, 2024 Author Posted January 16, 2024 This would involve active participants who have not yet reached NRA. My understanding is they would like to offer active participants the opportunity to receive a lump sum, and if they do, they will no longer accrue benefits. For those who don't take the lump sum, they would still accrue benefits. The plan is partially frozen, so only the compensation element of the benefit formula can continue to grow.
david rigby Posted January 16, 2024 Posted January 16, 2024 Have I missed something? What is the distributable event? Luke Bailey, Effen and Lou S. 3 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.
Effen Posted January 17, 2024 Posted January 17, 2024 As Dave alluded to, you can't just offer lump sums to actives because "they would like to". There has to be a distributable event - attainment of normal retirement age, plan termination, death, disability, retirement, etc. I think you can slide down the in-service distribution age to 59.5, but not younger than that without terminating the plan. Regarding freezing accruals for those who take the lump sum prior to NRD, it seems like as long as the effect of the amendment is non-discriminatory, you could do it. I would make sure you accurately disclose everything to the participants, then it is their choice, but it feels pretty scummy. You would also be required to show the plan is non-discriminatory every year thereafter since they froze accruals for non-excludable participants. acm_acm and Luke Bailey 2 The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
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