Tom Finnegan

Are ERFs BRFs? (Or, Can I Use Different Interest Credit Rates for HCEs and NHCEs?)

By Tom Finnegan 11/16/2016

Recently, cash balance designs have emerged in which the HCEs of the sponsor receive a lower interest credit rate for their hypothetical accounts than do the NHCEs. This is done frequently as a compromise for sponsors that wish to provide a realistic account return for employees while limiting the... READ MORE

Proposed Regulation Under Section 401(a)(4)

By Tom Finnegan 3/15/2016

For the last several weeks, the community of pension professionals has been focused on the potential impact of proposed changes to the general test under Code Section 401(a)(4). The proposed changes would require that in order for a rate group to meet the general test using the Average Benefits... READ MORE

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Tom Finnegan

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