Overview
David Rogers, Stephen Pavlick and Brian Benko authored this comment to the IRS on proposed and final hybrid retirement plan regulations addressing interest crediting rates that are now considered to be above market but were adopted before the Pension Protection Act of 2006 in connection with the settlement of cash balance plan whipsaw litigation. The authors submitted their comment on behalf of a client plan sponsor whose cash balance plan is affected by above-market interest crediting rates, adding that “we believe other plans face similar issues.”
