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Pension Plan Sponsors Must Justify the Reasonableness of Normal Retirement Ages Under Age 62 (PDF)
PrudentialLink to more items from this source
[Guidance Overview]
Feb. 5, 2015

"Plan sponsors that have submitted determination letter requests using the most recent version of Form 5300 ... may have noticed a new line item 5 ... If the plan is [1] Any type of defined benefit plan, including a cash balance or pension equity plan (PEP); or [2] A defined contribution money purchase plan or target benefit plan, it must indicate if the plan's NRA has been below age 62 at any time after May 22, 2007. If the answer is 'yes', the next question is whether the employer ... has made a good faith determination that this NRA reasonably represents the typical retirement age for the industry in which the covered workforce is employed. If such a determination has been made, a special statement must be attached to the Form 5300 submission."

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