"For sponsors of individually designed cash balance and other statutory hybrid plans, [Rev. Proc. 2019-20] provides an important but time-limited opportunity to confirm whether their plan documents are fully compliant with the final cash balance regulations, including the IRS' requirements for using a 'market rate of return' for a plan's interest crediting rate.... Sponsors of traditional defined benefit plans that may be considering converting to a cash balance or other hybrid formula should consider whether it may make sense to effectuate the conversion on or before August 31, 2020, in order to take advantage of this limited opportunity from the IRS."

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