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Posted

Hi. Under our cash balance plan, a contribution doesn’t receive interest until February of the following plan year.  For example, a 2023 contribution will start to receive interest credit in February of 2024.  We would like to amend the plan to eliminate the 1 month delay and have contributions receive the interest credit starting on January 1 of the following plan year.  Would it be permissible to make this amendment retroactively effective to January 1, 2024? 

Thanks.

Posted

What?

Are you saying that the pay credit for any given year only gets 11/12ths of the following year's interest credit, while the rest of the hypothetical account balance gets the full interest credit? I have never heard of something like this. Is this a preapproved document?

If I'm understanding this correctly, I don't see any problem with your proposed amendment, just be aware since the amendment will increase the funding target, it would be restricted if the AFTAP is less than 80% or if it would cause the AFTAP to fall below 80%. I can't imagine the AFTAP would be impacted much by adding 1 month of interest credit to the funding target, but just in case.

Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance.

Corey B. Zeller, MSEA, CPC, QPA, QKA
Preferred Pension Planning Corp.
corey@pppc.co

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