CuseFan Posted March 5, 2020 Posted March 5, 2020 Client has frozen plan with a subsidized lump sum interest rate using the 30-year Treasury less 50 bp. Plan is currently partially restricted under IRC 436, but in the current environment lump sums are valued at 1.16% - OUCH! Does anyone have experience with or knowledge of getting a PLR allowing removal/changing of an unsustainable provision such as this? We know this is otherwise protected, but in the interest of protecting the future viability of the Plan we are looking into options. Thanks Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
Calavera Posted March 5, 2020 Posted March 5, 2020 I recall you can change lump sum interest rates, but have to protect it for a year providing greater of. See Rev. Proc. 99-23 and prior discussion https://benefitslink.com/boards/index.php?/topic/5458-transition-to-gatt-lump-sums/
CuseFan Posted March 5, 2020 Author Posted March 5, 2020 Thanks, but that trail appears to apply to statutory minimums and the timing of amendments to comply, remedial amendment periods and such. You can change things like the lookback month and protect the greater of for a year, but this is totally different. I know we could change for prospective accruals, but the plan is frozen so that doesn't matter. Thanks anyway. Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
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