Who is a participant for F5500 C/R

This question goes to the definition of "active participant" in the f5500 instructions for a pension plan. My client received a $2 mill age 70 415 lump sum in 2012 under the C-limit, but he continues to work and is still accruing service and comp credits, BUT it is unlikely that he will ever be able to accrue additional benefits. His comp is $350k per year. I ran a MASD analysis and he is still about 10% away from ability to accrue. My question is: should he be listed as a participant on the Form 5500CR. On the SB he would not be listed as a participant since he has no current benefits.

I would say he's still a participant with a right to accrue future benefits. Though his current benefit is $0 due to the offset from the prior payout.

1 hour ago, VeryOldMan said:

 On the SB he would not be listed as a participant since he has no current benefits.

Really?

 instructions say to include those who are currently accruing or who will accrue benefits in the future. Since he might not accrue benefits in the future, I wasn't sure to list as a participant on the SB. A an afterthought and your remark, unless I could prove he would never accrue, I think I should include him.

Who says you can't teach a (very) old dog!  Happy New Year! As an afterthought of my own keep in mind that an actuary, as part of the funding method, can choose to include all or a portion of those who are not yet participants in the valuation.  If that happens  then the actuary essentially treats those who have not yet entered the plan as active under the terms of the plan.  Finally, if the formula would establish an accrued benefit as of the beginning of the year for such a "participant" the item 3 body count and the Funding Target could be higher than expected.