415 Dollar Limit

[redsoxnation]

Thanks Rick.

[gunhog]

Moving away from NDT and back to exams.

Question 10 of EA-2A 2010 is a relatively straight-forward S415 limit question for a participant retiring at age 68. However the question includes this statement: "The plan does not suspend benefits for participants who work beyond NRA."

What I'm wondering is how the solution would change if this statement was not present in the question.

Thanks.

[davefarber]

Originally Posted by gunhog

Moving away from NDT and back to exams.

Question 10 of EA-2A 2010 is a relatively straight-forward S415 limit question for a participant retiring at age 68. However the question includes this statement: "The plan does not suspend benefits for participants who work beyond NRA."

What I'm wondering is how the solution would change if this statement was not present in the question.

Thanks.

If the benefit was suspended at age 65, then there would be no difference between the age 65 and age 68 benefits -- making the actuarial equivalence factor under plan assumptions equal to 1. So there would be no change in the dollar limit at age 68. By the way, if they had left that statement out of the question, I would still have solved it as if there was no suspension of benefits, since there is no general condition about that, and to assume that there was a suspension of benefits would be reading something into the question that is not there. Most likely, whoever wrote that question had thought about that issue, though -- maybe it had come up for them in real life.

[ak2ary]

I am sure both Rick and Dave would agree that, regardless of whther the plan allows the frozen benfits to increase to the 415 limit post benefit freeze, if as of the date of the original freeze the participant has less than ten years of plan participation, the proration of the maximum for the short participation does not increment during the freeze.

That is if the participant had only 7 years participation as of the original freeze date he would be entitled to 7/10ths of the otherwise calculated 415(b) limit. That fraction would not increment even if the plan allows the 415 limit to adjust. This is because a year of participation is only granted for a period for which the plan grants benefit accruel service.

[davefarber]

Originally Posted by ak2ary

I am sure both Rick and Dave would agree that, regardless of whther the plan allows the frozen benfits to increase to the 415 limit post benefit freeze, if as of the date of the original freeze the participant has less than ten years of plan participation, the proration of the maximum for the short participation does not increment during the freeze.

That is if the participant had only 7 years participation as of the original freeze date he would be entitled to 7/10ths of the otherwise calculated 415(b) limit. That fraction would not increment even if the plan allows the 415 limit to adjust. This is because a year of participation is only granted for a period for which the plan grants benefit accruel service.

Yes, I agree. See regulation 1.415(b)-1(g)(1)(ii)(A).

[redsoxnation]

Tom (or Dave), do you have any thoughts on the 410(b) or 401(a)(4) testing ramifications of adjusting frozen benefit for indexing of the 415 dollar limit?