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Posted

When general testing for nondiscrimination, must you use the same measurement period (current year versus accrued to date) for your rate group determination and for the average benefits percentage? That is, can I determine accrual rates for rate groups on an accrued to date basis but calculate my average benefits percentage on a current accrual basis, because I don't have the DC balances, only current year contributions - or do I need to get balances and use same basis?

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

Posted

Consider a plan that is restructured for rate groups such that one restructured "plan" uses current year testing and another restructured "plan" uses accrued-to-date testing.  Keep in mind that there is only one average benefits test.  Does that make it clear?

Posted

I think so. in your example, I presume, you could do the ABT on either basis as you choose and regardless, one would be on a different basis than how the rate groups are determined - so i conclude that rate groups and ABT need not be determined on the same measurement period basis. Same page? Thanks

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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