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Posted

Client has integrated final pay plan that they plan to freeze at end of current year. However, they would also like to credit all active participants as of that time with an additional year of service. So if someone has 20.667 years of credited service (they use elapsed time), they would be bumped up to 21.667. Plan satisfies coverage and integrated formula is 401(l) compliant (1% /.5% at $4800).  Does giving everyone an additional YOS mess up my integration and force me to general test, or am I still safe harbor because everyone gets it? Any other potential traps for concern? 

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

Posted

Hmmm.  "Everyone gets it" does not automatically make something safe harbor, or non-discriminatory.  I'm not sure if the proposal will cause a failure of 401(l), but I suspicious.  At any rate, if the proposed additional service is restricted to the "base" portion of the benefit, it should be acceptable. 

However, I'm interested in why this is being proposed.  Is it to "use up" some excess assets?  There are multiple ways to address that.

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.

  • 3 months later...
Posted

I believe this screws up 401(l).  A person with one year going to two would exceed the maximum disparity in one year for an excess plan(2%/1%). I think you would need to general test..

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