Audrey Posted June 25, 2024 Posted June 25, 2024 the stability period always starts on 1/1 for 417(e) purpose and it starts on the valuation date for funding assumption purpose. am I understanding it correctly? tried to find the regulation about the definition but can't find the specific definition of the start date.
C. B. Zeller Posted June 25, 2024 Posted June 25, 2024 For distributions, the stability period can be the plan year, calendar year, plan quarter, calendar quarter, or calendar month containing the distribution date. The applicable interest rate can be determined as of the 1st, 2nd, 3rd, 4th or 5th month preceding the stability period, or may be an average of interest rates during those months. See 1.417(e)-1(d)(4). For funding, the segment rates are the ones published for the applicable month, which is the month containing the valuation date. However the plan sponsor may elect an alternative applicable month of one of the 4 months preceding the month containing the valuation date. The plan sponsor may also elect to use the corporate bond yield curve instead of the segment rates. Once an election is made, it may only be changed or revoked with IRS approval. See 1.430(h)(2)-1(e). Luke Bailey, Audrey, Effen and 1 other 4 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
Audrey Posted June 25, 2024 Author Posted June 25, 2024 4 hours ago, C. B. Zeller said: For distributions, the stability period can be the plan year, calendar year, plan quarter, calendar quarter, or calendar month containing the distribution date. The applicable interest rate can be determined as of the 1st, 2nd, 3rd, 4th or 5th month preceding the stability period, or may be an average of interest rates during those months. See 1.417(e)-1(d)(4). For funding, the segment rates are the ones published for the applicable month, which is the month containing the valuation date. However the plan sponsor may elect an alternative applicable month of one of the 4 months preceding the month containing the valuation date. The plan sponsor may also elect to use the corporate bond yield curve instead of the segment rates. Once an election is made, it may only be changed or revoked with IRS approval. See 1.430(h)(2)-1(e). hi Corey, thank you so much for these info! for distributions - for example, the distribution date is 7/15/2024, if the stability period is the plan year with 1st month lookback, then stability period is 2024 plan year and the applicable month is December 2023; if the stability period is calendar month with 1st month lookback, then stability period is July 2024 and the applicable month is June 2024. Am I understanding these correctly?
C. B. Zeller Posted June 25, 2024 Posted June 25, 2024 Assuming that the plan year is the calendar year, then I agree. Audrey 1 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
Audrey Posted June 26, 2024 Author Posted June 26, 2024 20 hours ago, C. B. Zeller said: Assuming that the plan year is the calendar year, then I agree. thank you so much Corey!
david rigby Posted June 26, 2024 Posted June 26, 2024 The explanation from @C. B. Zeller is great. But also take note: both stability period and lookback month should be defined in the plan document. using a one-month stability period and one-month lookback will (generally) provide the closest to "true market value", but that combination is the most difficult to administer. Most plans I've seen use the PY as the stability period, often with a lookback month of "second month preceding". Audrey and Luke Bailey 2 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.
Audrey Posted June 26, 2024 Author Posted June 26, 2024 22 minutes ago, david rigby said: The explanation from @C. B. Zeller is great. But also take note: both stability period and lookback month should be defined in the plan document. using a one-month stability period and one-month lookback will (generally) provide the closest to "true market value", but that combination is the most difficult to administer. Most plans I've seen use the PY as the stability period, often with a lookback month of "second month preceding". Thank you David!
truphao Posted June 26, 2024 Posted June 26, 2024 while most of the plans (especially small ones) are using PY as stability period, the choice of the lookback is really a consulting issue. For example month of September has a tendency to be the "lowest rates" month, if you want to be able to time/plan "things" better, August gives the most flexibility, if you have to process distirbutions in January the month of December is not a good choice, etc. Audrey and Luke Bailey 2
Audrey Posted June 27, 2024 Author Posted June 27, 2024 13 hours ago, truphao said: while most of the plans (especially small ones) are using PY as stability period, the choice of the lookback is really a consulting issue. For example month of September has a tendency to be the "lowest rates" month, if you want to be able to time/plan "things" better, August gives the most flexibility, if you have to process distirbutions in January the month of December is not a good choice, etc. Thank you so much for the details!!!
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