"[B]ecause it is based on actuarial assumptions tied to [DB] plan benefit limits, the [maximum permitted allocation (MPA)] will, in reality, likely be far lower than $3 million -- both if interest rates return to historic averages and (even if interest rates remain at historic lows) for younger workers.... [T]he fact that the MPA is as high as $3 million in today's interest rate environment is an historical aberration."

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