Draper55 Posted July 11, 2024 Posted July 11, 2024 Suppose a participant in a traditional db plan terminated employment 10/31 and has an annuity starting date of 11/1. If they receive two months of severance comp which is not paid until 12/31 can that comp be included in the accrued benefit as of 10/31 and become part of the first payment on 11/1? If the severance comp is paid in the final 10/31 pay I think clearly it is okay. The first scenario does not seem correct to me but I cannot say why precisely. Would it be different though if the benefit calculation is done after 12/31 with a RASD to 11/1? The plan document says that the accrued benefit is as of a date but compensation seems to be related to the plan year?
CuseFan Posted July 11, 2024 Posted July 11, 2024 True "severance" pay is never Plan Compensation and is different from statutory post-severance compensation. If a person receives a "separation bonus" as part of their last paycheck, that may be includable depending on the terms of the plan - but if it's classified as severance it is ignored in any scenario. If this is includable post-severance compensation, and is not known until after the ASD, often a person is put into pay status based on the known (but incomplete) compensation amount and then after a final accurate benefit is calculated the future benefit payments are adjusted along with a true-up payment. Or, forms and elections are made using the aforementioned estimate prior to the ASD but then commencement is delayed for administrative reasons as the final actual benefit gets calculated and then paid effective back to the ASD. This is NOT an RASD if the QJSA forms are provided to the participant prior to the ASD. Plan language must specifically provide for an RASD and there are certain rules you must follow in calculating and communicating benefits. Luke Bailey, Bri and Effen 3 Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
david rigby Posted July 12, 2024 Posted July 12, 2024 True dat. Also, remember that many severance payments are made via payroll: in this case, the former employee is left on the payroll as a simple mechanism of making severance payments beyond the severance of employment date. This is mechanical in nature and does not define that person as an "active employee". Luke Bailey and Bri 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.
Recommended Posts
Create an account or sign in to comment
You need to be a member in order to leave a comment
Create an account
Sign up for a new account in our community. It's easy!
Register a new accountSign in
Already have an account? Sign in here.
Sign In Now