[Federal Register Volume 91, Number 160 (Thursday, August 20, 2026)]
[Proposed Rules]
[Pages 53803-53811]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2026-17021]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-107855-25]
RIN 1545-BR50
Determination of Target Normal Cost and Funding Target for
Single-Employer Defined Benefit Plans
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking.
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SUMMARY: This document contains proposed regulations that would modify
[[Page 53804]]
rules in the existing regulations relating to the minimum funding
requirement applicable to single-employer defined benefit pension
plans. The modifications include changes to the rules relating to the
determination of a plan's target normal cost and funding target and
would implement certain statutory amendments that have not yet been
reflected in the regulations. These proposed regulations would affect
participants in, beneficiaries of, employers maintaining, and
administrators of single-employer defined benefit plans.
DATES: Written or electronic comments and requests for a public hearing
must be received by October 19, 2026.
ADDRESSES: Commenters are strongly encouraged to submit public comments
electronically. Submit electronic submissions via the Federal
eRulemaking Portal at https://www.regulations.gov (indicate IRS and
REG-107855-25) by following the online instructions for submitting
comments. Requests for a public hearing must be submitted as prescribed
in the ``Comments and Requests for a Public Hearing'' section. Once
submitted to the Federal eRulemaking Portal, comments cannot be edited
or withdrawn. The Department of the Treasury (Treasury Department) and
the IRS will publish for public availability any comment received to
its public docket. Send paper submissions to: CC:PA:01:PR (REG-107855-
25), Room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin
Station, Washington, DC 20044.
FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations,
Tom Morgan at (202) 317-6700; concerning submissions of comments and
requests for a public hearing, contact the Publications and Regulations
Section at (202) 317-6901 (not a toll-free number) or by email to
[email protected] (preferred).
SUPPLEMENTARY INFORMATION:
Authority
The proposed regulations are issued under the delegation of
authority in section 430(g)(3)(B) of the Internal Revenue Code (Code),
which provides that a plan may determine the value of plan assets on
the basis of the averaging of fair market values, but only if that
method is permitted under regulations prescribed by the Secretary of
the Treasury or the Secretary's delegate (Secretary); and section
430(h)(3), which provides that, generally, the Secretary shall
prescribe by regulation mortality tables to be used in determining any
present value or making any computation under section 430.
In addition, the proposed regulations are issued under the
delegation of authority in section 7805. Section 7805(a) directs the
Secretary of the Treasury or his delegate to prescribe all needful
rules and regulations for the enforcement of that section and other
provisions of the Code, including such rules and regulations as may be
necessary by reason of any alteration of law relating to internal
revenue.
Background
This document contains proposed amendments to the Income Tax
Regulations (26 CFR part 1) under section 430 of the Code, which was
added by the Pension Protection Act of 2006, Public Law 109-280, 120
Stat. 780 (2006). The proposed amendments to the regulations primarily
reflect changes to section 430 of the Code made by: (1) the Worker,
Retiree, and Employer Recovery Act of 2008 (WRERA `08), Public Law 110-
458, 122 Stat. 5092 (2008); (2) the Setting Every Community Up for
Retirement Enhancement Act of 2019 (SECURE Act), Division O of the
Further Consolidated Appropriations Act, 2020, Public Law 116-94, 133
Stat. 2534 (2019); and (3) the SECURE 2.0 Act of 2022 (SECURE 2.0 Act),
Division T of the Consolidated Appropriations Act, 2023, Public Law
117-328, 136 Stat. 4459 (2022).
A. Plan Qualification Timing Rules Under Section 401(b)
Section 401(b)(1), as amended by section 201 of the SECURE Act,
provides that a plan is considered as satisfying the qualification
requirements of section 401(a) for the period beginning with the date
on which it was put into effect, or for the period beginning with the
earlier of the date on which there was adopted or put into effect any
amendment that caused the plan to fail to satisfy those requirements,
and ending with the time prescribed by law for filing the return of the
employer for his taxable year in which the plan or amendment was
adopted (including extensions) or any later time as the Secretary may
designate, if all provisions of the plan that are necessary to satisfy
those requirements are in effect by the end of that period and have
been made effective for all purposes for the whole of that period.
Section 401(b)(2), as added by section 201 of the SECURE Act and
amended by Section 317 of the SECURE 2.0 Act, provides that if an
employer adopts a plan after the close of a taxable year but before the
time prescribed by law for filing the return of the employer for the
taxable year (including extensions), then the employer may elect to
treat the plan as having been adopted as of the last day of the taxable
year.
Section 401(b)(3), as added by Section 316 of the SECURE 2.0 Act,
provides that if (A) an employer amends a plan to increase benefits
accrued under the plan effective as of any date during the immediately
preceding plan year (other than increasing the amount of matching
contributions), (B) that amendment would not otherwise cause the plan
to fail to meet any of the requirements of sections 401 through 436 of
the Code, and (C) that amendment is adopted before the time prescribed
by law for filing the return of the employer for the taxable year
(including extensions) which includes the effective date of the
amendment, then the employer may elect to treat that amendment as
having been adopted as of the last day of the plan year in which the
amendment is effective.
Section 1.401(b)-1 provides rules regarding remedial amendments
under section 401(b). Under Sec. 1.401(b)-1(a), a plan that does not
satisfy the requirements of section 401(a) on any date solely as a
result of a disqualifying provision (as determined under Sec.
1.401(b)-1(b)) is considered to have satisfied those requirements on
that date if, on or before the end of the remedial amendment period (as
defined in Sec. 1.401(b)-1(d) through (f) with respect to the
disqualifying provision), all provisions of the plan that are necessary
to satisfy all requirements under section 401(a) are in effect and have
been made effective for all purposes for the entire remedial amendment
period. The second sentence of Sec. 1.401(b)-1(a) notes that under
some facts and circumstances, it may not be possible to amend a plan
retroactively so that all provisions of the plan which are necessary to
satisfy the requirements of section 401(a) are in fact made effective
for the whole remedial amendment period.\1\
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\1\ In these circumstances, the plan would have to be operated
in accordance with the expected future amendment prior to when the
amendment is adopted.
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Pursuant to Sec. 1.401(b)-1(d)(2), the remedial amendment period
generally ends with the time prescribed by law, including extensions,
for filing the income tax return (or partnership return of income) of
the employer for the employer's taxable year in which falls the latest
of: (1) the date on which the remedial amendment period begins, (2) the
date on which the disqualifying provision is adopted, or (3) the date
on
[[Page 53805]]
which the disqualifying provision is made effective. However, under
Sec. 1.401(b)-1(d)(2), the Commissioner may extend the remedial
amendment period.
Revenue Procedure 2022-40, 2022-47 I.R.B. 487, extended the
expiration of the remedial amendment period for a disqualifying
provision with respect to a provision of a new plan or the absence of a
provision from a new plan to the last day of the second calendar year
following the calendar year in which the plan is put into effect. In
addition, many deadlines for plan amendments made pursuant to specific
legislative changes have been further extended in the corresponding
legislation. See, for example, section 501 of the SECURE 2.0 Act.
B. Minimum Funding Requirements and Related Provisions for Single-
Employer Defined Benefit Plans
Statutory Provisions
Section 412 provides minimum funding requirements that generally
apply for pension plans (including both defined benefit pension plans
and money purchase pension plans). Pursuant to section 412(a)(2)(A),
section 430 specifies the minimum funding requirements that apply to
single-employer defined benefit pension plans (including multiple-
employer plans) other than CSEC plans described in section 414(y).
Section 412(d)(1) provides that if the funding method or a plan
year for a plan is changed, the change will take effect only if
approved by the Secretary.\2\ Section 412(d)(2) provides that, for
purposes of section 412, any amendment applying to a plan year which is
adopted no later than 2\1/2\ months after the close of the plan year
(or, in the case of a multiemployer plan, no later than 2 years after
the close of such plan year), does not reduce the accrued benefit of
any participant determined as of the beginning of the first plan year
to which the amendment applies, and does not reduce the accrued benefit
of any participant determined as of the time of adoption except to the
extent required by the circumstances, will, at the election of the plan
administrator, be deemed to have been made on the first day of the plan
year.
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\2\ The Secretary has prescribed procedures allowing plans
subject to section 412 to receive automatic approval to change their
funding method in limited circumstances. See Rev. Proc. 2017-56,
2017-44 IRB 465 (applicable to single-employer plans), and Rev.
Proc. 2000-40, 2000-42 IRB 357 (applicable to multiemployer plans).
The Secretary has also prescribed procedures allowing plans to
receive automatic approval to change their plan year if certain
conditions are met. See Rev. Proc. 87-27, 1987-1 CB 769, as amended
by Ann. 88-97, 1988-26 IRB 47.
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Under section 430, the minimum required contribution for a plan
year is a function of the target normal cost under section 430(b)(1),
shortfall amortization charge under section 430(c)(1), funding target
under section 430(d)(1), waiver amortization charge under section
430(e)(1), and value of plan assets under section 430(g)(3). If the
value of plan assets (less the sum of the plan's prefunding balance and
funding standard carryover balance determined under section 430(f)) is
less than the funding target, section 430(a)(1) defines the minimum
required contribution as the sum of the plan's target normal cost and
the shortfall and waiver amortization charges for the plan year. If the
value of plan assets (less the sum of the plan's prefunding balance and
funding standard carryover balance) equals or exceeds the funding
target, section 430(a)(2) defines the minimum required contribution as
the plan's target normal cost for the plan year reduced (but not below
zero) by the amount of any such excess.
Section 430(b)(1) as amended by WRERA `08, provides that, except as
otherwise provided in section 430(i)(2) (regarding a plan that is in
at-risk status), a plan's target normal cost for a plan year is the sum
of the present value of all benefits expected to accrue or be earned
under the plan during the plan year (with any increase in any benefit
attributable to services performed in a preceding plan year by reason
of a compensation increase during the current plan year treated as
having accrued during the current plan year) and the amount of plan-
related expenses expected to be paid from plan assets during the plan
year, reduced by the amount of mandatory employee contributions
expected to be made during the plan year.
Section 430(d)(1) provides that, except as otherwise provided in
section 430(i)(1) (regarding a plan that is in at-risk status), a
plan's funding target for a plan year is the present value of all
benefits accrued or earned under the plan as of the beginning of the
plan year.
Under section 430(h)(5), if, with respect to a single-employer
defined benefit plan, the aggregate unfunded vested benefits as of the
close of the preceding plan year (combined with the unfunded vested
benefits for all other plans maintained by the contributing sponsors
and members of such sponsors' controlled groups) exceeded $50 million,
then certain changes in actuarial assumptions must be approved by the
Secretary. The changes in actuarial assumptions that require approval
are changes that result in a decrease in the funding shortfall of the
plan for the current plan year (determined after taking into account
any changes in interest rate and mortality table) that exceeds $50
million (or that exceeds $5 million and that is 5 percent or more of
the funding target of the plan before that change).
Section 404(o)(6) provides that any computations under section
404(o), which relates to the deduction for contributions to a single-
employer defined benefit plan, must use the same actuarial assumptions
that are used for the plan year under section 430, except that the
interest rate corridor under section 430(h)(2)(C)(iv) does not apply,
and section 404(o)(7) provides that any term used in section 404(o)
which is also used in section 430 has the same meaning given to that
term by section 430. Thus, except for the difference in interest rates,
the funding target and target normal cost under section 430 (determined
taking into account plan provisions that are recognized under the rules
of section 430) are also used to determine the maximum deductible
contributions under section 404(o).
Section 436(c)(1) provides that, generally, no amendment to a
defined benefit plan which is a single-employer plan which has the
effect of increasing liabilities of the plan by reason of increases in
benefits, establishment of new benefits, changing the rate of benefit
accrual, or changing the rate at which benefits become nonforfeitable
may take effect during any plan year if the adjusted funding target
attainment percentage (AFTAP) for such plan year is less than 80
percent, or would be less than 80 percent taking into account the
amendment.\3\ However, section 436(c)(2) provides that such an
amendment can take effect if the plan sponsor makes a contribution (in
addition to the minimum required contribution) equal to the amount of
the increase in the funding target of the plan for the plan year
attributable to the amendment (if the AFTAP is less than 80 percent) or
(in other cases) the amount necessary to result in an AFTAP of 80
percent.
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\3\ Section 436(c)(3) provides for a limited exception for
certain benefit increases under a formula which is not based on a
participant's compensation.
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Regulatory Provisions
On October 15, 2009, final regulations regarding the determination
of the target normal cost under section 430(b) and the funding target
under section 430(d) were published in the Federal Register
[[Page 53806]]
(TD 9467, 74 FR 53004). Those regulations apply to plan years beginning
on or after January 1, 2010.
Section 1.430(d)-1(b)(1)(i) provides that, subject to the
adjustments in Sec. 1.430(d)-1(b)(1)(iii), the target normal cost of a
defined benefit plan that is not in at-risk status under section 430(i)
for a plan year is the present value (determined as of the valuation
date) of all benefits under the plan that accrue during, are earned
during, or are otherwise allocated to service for the plan year.
Section 1.430(d)-1(b)(1)(iii)(A) provides that the target normal
cost of the plan for the plan year is adjusted (not below zero) by
adding the amount of plan-related expenses expected to be paid from
plan assets during the plan year and subtracting the amount of
mandatory employee contributions that are expected to be made during
the plan year. Section 1.430(d)-1(b)(1)(iii)(B) is reserved for a
definition of plan-related expenses.
Under Sec. 1.430(d)-1(d)(1)(i), a plan's funding target and target
normal cost for a plan year generally are determined based on plan
provisions that are adopted no later than the valuation date for the
plan year and that take effect on or before the last day of the plan
year.
Section 1.430(d)-1(d)(1)(ii) provides rules regarding the impact of
an election under section 412(d)(2), which is available with respect to
a plan amendment adopted no later than 2\1/2\ months after the close of
the plan year (including an amendment adopted during the plan year).
Under Sec. 1.430(d)-1(d)(1)(ii), if a plan administrator makes the
election described in section 412(d)(2) with respect to a plan
amendment, then the plan amendment is treated as having been adopted on
the first day of the plan year for purposes of Sec. 1.430(d)-1(d).
However, because a section 412(d)(2) election merely deems the
amendment to have been made on the first day of the plan year, it does
not determine when the plan amendment takes effect. Accordingly,
regardless of whether a section 412(d)(2) election is made, an
amendment is taken into account for the plan year only if it takes
effect by the last day of the plan year.
Section 1.430(d)-1(d)(1)(iii) provides that, for purposes of Sec.
1.430(d)-1(d)(1), the determination of whether an amendment that
increases benefits takes effect and when it takes effect is determined
in accordance with the rules of section 436(c) and Sec. 1.436-1(c)(5).
Section 1.436-1(c)(5) provides that, for purposes of section 436(c) and
Sec. 1.436-1(c), in the case of an amendment that increases benefits,
the amendment takes effect under a plan on the first date on which any
individual who is or could be a participant or beneficiary under the
plan would obtain a legal right to the increased benefit if the
individual were on that date to satisfy the applicable requirements for
entitlement to the benefit (such as the attainment of any age,
performance of any service, receipt or derivation of any compensation,
or the occurrence of death, disability, or severance from employment).
Section 1.430(d)-1(d)(1)(iii) similarly provides that in the case of an
amendment that decreases benefits, the amendment takes effect under a
plan on the first date on which the benefits of any individual who is
or could be a participant or beneficiary under the plan would be less
valuable than those benefits would be under the pre-amendment plan
provisions if the individual were on that date to satisfy the
applicable conditions for the benefits.
Section 1.430(d)-1(d)(2) provides that, in the case of a plan
amendment that is not required to be taken into account under the rules
of Sec. 1.430(d)-1(d)(1) because it is adopted after the valuation
date for the plan year, the plan amendment must be taken into account
in determining a plan's funding target and target normal cost for the
plan year if the amendment (i) takes effect by the last day of the plan
year; (ii) increases the liabilities of the plan by reason of increases
in current benefits, establishment of new benefits, changing the rate
of benefit accrual, or changing the rate at which benefits become
nonforfeitable; and (iii) would not be permitted to take effect under a
modified version of the rules of section 436(c). The modified version
of the section 436(c) rules is set forth in Sec. 1.430(d)-
1(d)(2)(iii), which provides that those rules are applied by treating
the increase in the target normal cost for the plan year attributable
to the amendment (and all other amendments that must be taken into
account solely because of the application of the rules in Sec.
1.430(d)-1(d)(2)) as if the increase were an increase in the funding
target for the plan year, and by taking into account all unpredictable
contingent event benefits permitted to be paid for unpredictable
contingent events that occurred during the current plan year and all
plan amendments that took effect in the current plan year (including
all amendments to which Sec. 1.430(d)-1(d)(2) applies for the plan
year).
C. Actuarial Assumptions
Section 1.430(d)-1(f)(1)(i) provides that the determination of any
present value or other computation under section 430 and this section
must be made on the basis of actuarial assumptions and a funding
method. Section 1.430(d)-1(f)(1)(ii) provides that actuarial
assumptions established for a plan year cannot subsequently be changed
for that plan year unless the Commissioner determines that the
assumptions that were initially used are unreasonable. Similarly, a
funding method established for a plan year cannot subsequently be
changed for that plan year unless the Commissioner determines that the
initial use of that funding method for that plan year is impermissible.
Section 1.430(d)-1(f)(1)(iii) provides that generally, the actuarial
assumptions and funding method for a plan year are established by the
filing of an actuarial report under section 6059 (Schedule SB of Form
5500, Annual Return/Report of Employee Benefit Plan).
Section 1.430(d)-1(f)(3) provides that, in the case of actuarial
assumptions other than those specified in sections 430(h)(2),
430(h)(3), and 430(i), each of those actuarial assumptions must be
reasonable (taking into account the experience of the plan and
reasonable expectations). In addition, the actuarial assumptions (other
than those specified in sections 430(h)(2), 430(h)(3), and 430(i))
must, in combination, offer the plan's enrolled actuary's best estimate
of anticipated experience under the plan based on information
determined as of the valuation date.
Section 1.430(d)-1(f)(4)(ii) provides that any determination of
present value or any other computation under that section must take
into account the probability that future benefit payments under the
plan will be made in the form of any optional form of benefit provided
under the plan (including single-sum distributions), determined on the
basis of the plan's experience and other related assumptions, in
accordance with Sec. 1.430(d)-1(f)(3); and must take into account any
difference in the present value of future benefit payments that results
from the use of actuarial assumptions in determining the amount of
benefit payments in any such optional form of benefit that are
different from those prescribed by section 430(h).
Section 1.430(d)-1(f)(4)(iii)(A) provides that, in the case of a
distribution that is subject to section 417(e)(3) and that is
determined using the applicable interest rates and applicable mortality
table under section 417(e)(3), for purposes of applying Sec. 1.430(d)-
1(f)(4)(ii), the computation of the present value of that distribution
is treated as having taken into account any difference in present value
that results from the use of actuarial assumptions that are different
from those prescribed
[[Page 53807]]
by section 430(h) (as required under Sec. 1.430(d)-1(f)(4)(ii)(B)) if
and only if the present value of the distribution is determined in
accordance with Sec. 1.430(d)-1(f)(4)(iii).
Section 1.430(d)-1(f)(4)(iii)(B) provides that, generally, the
present value of a distribution is determined in accordance with Sec.
1.430(d)-1(f)(4)(iii) if that present value is determined as the
present value, using special actuarial assumptions, of the annuity
(either the deferred or immediate annuity) which is used under the plan
to determine the amount of the distribution. Under these special
assumptions, for the period beginning with the expected annuity
starting date for the distribution, the current applicable mortality
table under section 417(e)(3) that would apply to a distribution with
an annuity starting date occurring on the valuation date is substituted
for the mortality table under section 430(h)(3) that would otherwise be
used. In addition, under these special assumptions, the valuation
interest rates under section 430(h)(2) are used for purposes of
discounting the projected annuity payments from their expected payment
dates to the valuation date (as opposed to the interest rates under
section 417(e)(3), which the plan uses to determine the amount of the
benefit).
Section 1.430(d)-1(f)(4)(iii)(C) provides some alternative
assumptions that may be used in determining the present value of a
distribution under Sec. 1.430(d)-1(f)(4)(iii). In the case of a plan
for which the generational mortality tables are generally used to
determine present values under section 430(d), Sec. 1.430(d)-
1(f)(4)(iii)(C) allows for the use of a 50-50 male-female blend of the
annuitant mortality rates under the Sec. 1.430(h)(3)-1(a)(4)
generational mortality tables in lieu of the applicable mortality table
under section 417(e)(3).\4\ Section 1.430(d)-1(f)(4)(iii)(C) also
provides that adjustments to interest rates are permitted to take into
account the differences between the phase-in of the section 430(h)(2)
segment rates under section 430(h)(2)(G) and the adjustments to the
segment rates under section 417(e)(3)(D)(iii).
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\4\ The applicable mortality table under section 417(e)(3) is a
projected static mortality table, based on the mortality table
specified for the plan year under section 430(h)(3)(A) (without
regard to section 430(h)(3)(C) or (D)), modified as appropriate by
the Secretary.
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Section 1.430(d)-1(f)(5)(i) provides that, in the case of an
applicable defined benefit plan described in section 411(a)(13)(C), if
the amount of a future distribution is based on an interest adjustment
applied to the current accumulated benefit, then the amount of that
distribution is determined by projecting the future interest credits or
equivalent amount under the plan's interest crediting rules using
actuarial assumptions that satisfy the requirements of Sec. 1.430(d)-
1(f)(3).
Section 1.430(d)-1(f)(5)(ii)(A) provides that, in the case of an
applicable defined benefit plan described in section 411(a)(13)(C), if
the amount of an annuity distribution is based on either the balance of
a hypothetical account maintained for a participant or the accumulated
percentage of a participant's final average compensation, then the
amount of that annuity distribution is calculated by converting the
projected account balance (or accumulated percentage of final average
compensation), in accordance with Sec. 1.430(d)-1(f)(5)(i), to an
annuity by applying the plan's annuity conversion provisions using the
rules of Sec. 1.430(d)-1(f)(5)(ii).
Section 1.430(d)-1(f)(5)(ii)(B) provides that generally, if the
plan bases the conversion of the projected account balance (or
accumulated percentage of final average compensation) to an annuity
using the applicable interest rates and applicable mortality table
under section 417(e)(3), then the amount of the annuity distribution is
determined by dividing the projected account balance (or accumulated
percentage of final average compensation) by an annuity factor
corresponding to the assumed form of payment using, for the period
beginning with the annuity starting date, the current applicable
mortality table under section 417(e)(3) that would apply to a
distribution with an annuity starting date occurring on the valuation
date (in lieu of the mortality table under section 430(h)(3) that would
otherwise be used) and the valuation interest rates under section
430(h)(2) (as opposed to the interest rates under section 417(e)(3)
which the plan uses to determine the amount of the annuity).
Section 1.430(d)-1(f)(5)(ii)(C) provides that, in determining the
amount of an annuity distribution under Sec. 1.430(d)-1(f)(5)(ii)(B),
a plan is permitted to apply the optional applications of generational
mortality and phase-in of interest rates described in Sec. 1.430(d)-
1(f)(4)(iii)(C).
Explanation of Provisions
These proposed regulations would facilitate the adoption of
amendments that increase benefits. Under these proposed regulations,
such amendments adopted after the end of the plan year can be taken
into account in determining the actuarial results for a plan year
which, in turn, will result in an increased deductible limit for the
taxable year for the plan sponsor. These proposed regulations would
also: (1) clarify the plan-related expenses that are includable in
target normal cost; (2) provide rules for plans that are adopted after
the end of a plan year; (3) provide rules for when certain plan
amendments must be taken into account in the actuarial results for a
plan year; (4) extend the deadline for making certain changes in
actuarial assumptions or funding methods; and (5) make minor changes to
the rules for actuarial assumptions to eliminate references to
statutory provisions that are no longer applicable and to conform them
to other regulatory provisions.
A. Investment-Related Expenses Not Included in Target Normal Cost
Proposed Sec. 1.430(d)-1(b)(1)(iii)(B) would provide that plan-
related expenses consist of all amounts that are expected to be paid
from plan assets that are neither benefits paid to participants and
beneficiaries (treating the purchase of an annuity as the payment of
benefits), nor investment-related expenses described in proposed Sec.
1.430(d)-1(b)(1)(iii)(C).
Proposed Sec. 1.430(d)-1(b)(1)(iii)(C) would provide that
investment-related expenses consist of investment manager fees and
other expenses directly related to the investment of the plan's assets.
However, if the total payments from plan assets to a service provider
are expected to be $5,000 or more for a plan year and consist of both
investment-related expenses and expenses for other services (such as
recordkeeping services), only those amounts that the service provider
itemizes as investment management fees or other expenses directly
related to the investment of the plan's assets are treated as
investment-related expenses. Amounts itemized as expenses for other
services are not treated as investment-related expenses.\5\ An example
of other services would be if the assets of the pension fund are held
by a bank or trust company affiliated with the fund's investment
manager and the plan assets are used to pay custodial or trustee fees
for the safekeeping of the investment assets, such as holding
securities, settling trades, or collecting income. This exclusion means
that if the total payments from plan assets to a service provider are
expected to be less than $5,000, all payments are treated as
[[Page 53808]]
investment-related expenses and the service provider does not need to
itemize the expenses in order for the plan to exclude these payments
from target normal cost.
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\5\ This $5,000 threshold is consistent with the reporting
requirement on Form 5500, Schedule C for service providers who have
rendered services to, or who had transactions with, the plan during
the reporting year if the service provider received, directly or
indirectly, $5,000 or more in reportable compensation in connection
with services rendered or their position with the plan.
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B. Plans or Plan Amendments That Are Adopted After the End of the Plan
Year
Proposed Sec. 1.430(d)-1(d)(1) would provide rules for which plan
provisions are used to determine a plan's funding target and target
normal cost for a plan year based on when the plan provisions were
adopted and, if applicable, what election the plan administrator made.
For plan provisions adopted by the plan's valuation date, proposed
Sec. 1.430(d)-1(d)(1)(i) would provide that, except as otherwise
provided in proposed Sec. 1.430(d)-1(d)(1)(ii) and (iii), a plan's
funding target and target normal cost for a plan year are determined
based on plan provisions that are adopted no later than the valuation
date for the plan year and that take effect on or before the last day
of the plan year. For example, in the case of a plan amendment adopted
on or before the valuation date for the current plan year that has an
effective date occurring in the current plan year, the plan amendment
is taken into account in determining the funding target and the target
normal cost for the current plan year if it is permitted to take effect
under the rules of section 436(c) for the current plan year, but the
amendment is not taken into account for the current plan year if it
does not take effect until a future plan year.
For plan provisions adopted after the plan's valuation date, the
rules that apply are determined by the election made by the plan
administrator. Proposed Sec. 1.430(d)-1(d)(1)(ii)(A) would provide
that if the plan administrator makes an election under section
412(d)(2) with respect to a plan amendment that is adopted no later
than 2\1/2\ months after the end of the plan year, then the plan
amendment will be taken into account in determining the plan's funding
target and target normal cost for that plan year, provided that the
plan amendment takes effect no later than the date it is adopted. This
rule would apply even if the plan amendment were adopted during the
plan year, consistent with prior revenue rulings.\6\
---------------------------------------------------------------------------
\6\ See, for example, Rev. Rul. 79-325, 1979-2 C.B. 190.
---------------------------------------------------------------------------
Proposed Sec. 1.430(d)-1(d)(1)(ii)(B) would provide that if an
employer adopts a plan after the last day of the employer's taxable
year and before the due date for the employer's income tax return for
that taxable year (including extensions) and makes an election under
the first sentence of section 401(b)(2), then the plan is treated as
adopted on the last day of that taxable year. In such a case, the
target normal cost and funding target for the plan's first plan year
are determined based on the adopted plan provisions, provided that (1)
the plan takes effect no later than the date the plan is adopted; and
(2) if the plan's valuation date is before the date the plan is treated
as being adopted, a section 412(d)(2) election is made.
Proposed Sec. 1.430(d)-1(d)(1)(ii)(C) would provide that if,
before the due date (including extensions) for an employer's income tax
return for a taxable year, the employer adopts an amendment increasing
benefits accrued under a plan effective as of any date during the plan
year that immediately precedes the date of adoption, and makes an
election under section 401(b)(3) with respect to the plan amendment,
then the plan amendment is treated as having been adopted as of the
last day of that preceding plan year. In such a case, the target normal
cost and funding target for that preceding plan year are determined
taking the plan amendment into account, provided that (1) the amendment
takes effect no later than the date it is adopted, and (2) if the
plan's valuation date is before the date the amendment is treated as
being adopted, a section 412(d)(2) election is made.
Employers that make an election under either section 401(b)(2) or
section 401(b)(3) should note that the deadline for minimum required
contributions under section 430(j)(1) is 8\1/2\ months after the end of
the plan year, while the deadline for adopting a section 401(b)(2) or
section 401(b)(3) amendment under either proposed Sec. 1.430(d)-
1(d)(1)(ii)(B) or (C) can be after that deadline, depending on the
timing of the plan year and the employer's taxable year.
C. Remedial Amendments
Proposed Sec. 1.430(d)-1(d)(1)(iii) would provide rules under
which certain planned amendments are taken into account once plan
operations are changed pursuant to those planned amendments. The
existing rule in Sec. 1.430(d)-1(d)(1)(iii) would be revised as Sec.
1.430(d)-1(d)(1)(iv) and is discussed later in part C of this
Explanation of Provisions. Under proposed Sec. 1.430(d)-
1(d)(1)(iii)(A), if plan operations are changed during a remedial
amendment period (within the meaning of Sec. 1.401(b)-1(d)) to make
effective a future remedial amendment, then the provisions of the
future remedial amendment would be treated as adopted on the date that
the plan operations are changed. To the extent the actual remedial
amendment that is adopted is different from the way the plan has been
operated, the actual remedial amendment is treated as adopted when plan
operations are changed to reflect the actual remedial amendment (if
that change in plan operations occurs before the adoption date of the
amendment). For example, this could happen in the case of a plan that
is operated in accordance with a statutory change and then plan
operations are updated to reflect published guidance interpreting that
statutory change.
Proposed Sec. 1.430(d)-1(d)(1)(iii)(B) would provide that a plan
makes effective a future remedial amendment when (1) it is required to
be amended to address a disqualifying provision that has been
designated as such by the Commissioner pursuant to Sec. 1.401(b)-
1(b)(3), (2) the remedial amendment period with respect to that
required amendment has not ended, and (3) plan operations are changed
in anticipation of a proposed amendment to the plan relating to the
disqualifying provision.
Proposed Sec. 1.430(d)-1(d)(1)(iv) would provide substantially the
same rule as existing Sec. 1.430(d)-1(d)(1)(iii). However, proposed
Sec. 1.430(d)-1(d)(1)(iv) would not include the existing language
regarding the effect of an election made under section 412(d)(2), as
that issue would be separately addressed in proposed Sec. 1.430(d)-
1(d)(1)(ii)(A).
D. Anti-Abuse Rule for Mid-Year Amendments That Increase Target Normal
Cost Disproportionately
Proposed Sec. 1.430(d)-1(d)(2)(i) would modify the special rule in
existing Sec. 1.430(d)-1(d)(2) under which certain plan amendments
that are not required to be taken into account under the rules of Sec.
1.430(d)-1(d)(1), because the amendment is adopted after the valuation
date for the plan year, must nonetheless be taken into account in
determining a plan's funding target and target normal cost for the plan
year. A plan amendment would be subject to this rule if it (1)
increases the liabilities of the plan by reason of increases in current
benefits, establishment of new benefits, changing the rate of benefit
accrual, or changing the rate at which benefits become nonforfeitable;
(2) would not be permitted to take effect under the rules of section
436 as described in proposed Sec. 1.430(d)-1(d)(2)(ii); and (3) would
increase the target normal cost disproportionately, as described in
Sec. 1.430(d)-1(d)(2)(iii).
Under proposed Sec. 1.430(d)-1(d)(2)(i)(C), the anti-abuse rule in
[[Page 53809]]
Sec. 1.430(d)-1(d)(2) would apply only if the plan amendment increases
the target normal cost disproportionately. For this purpose, proposed
Sec. 1.430(d)-1(d)(2)(iii) would provide that a plan amendment
increases the target normal cost disproportionately if the percentage
increase in target normal cost as the result of the amendment is more
than twice the percentage increase in the funding target as a result of
the amendment (taking into account only the benefits of participants
currently employed in the service of the employer). Comments are
requested regarding other appropriate methods of measuring whether a
plan amendment is considered to increase the target normal cost
disproportionately, such as by comparing the present value of current
year accruals with the present value of accruals in succeeding plan
years.
E. Change in Actuarial Assumptions or Funding Method
Proposed Sec. 1.430(d)-1(f)(1)(ii) would revise the existing rule
in Sec. 1.430(d)-1(f)(1)(ii) to address the situation in which an
application to change actuarial assumptions or funding method has been
submitted to the Secretary,\7\ but the Secretary has not yet approved
the application when the assumptions or method are established for the
plan year. In these situations, the proposed regulations would be
amended to provide that the assumptions or funding method can be
changed for that plan year in accordance with the Secretary's approval
of that application.
---------------------------------------------------------------------------
\7\ Rev. Proc. 2017-57, 2017-44 I.R.B. 474, sets forth the
procedure for obtaining approval by the IRS for a change in the
funding method or actuarial assumptions used for a single-employer
defined benefit plan.
---------------------------------------------------------------------------
F. Other Rules Regarding Actuarial Assumptions
Proposed Sec. 1.430(d)-1(f)(4)(iii)(C) would provide rules for
determining the present value of a distribution under Sec. 1.430(d)-
1(f)(4)(iii) that are substantially the same as a rule in existing
Sec. 1.430(d)-1(f)(4)(iii)(C). However, the proposed rule would not
include the existing reference to the phase-in of the section 430(h)(2)
segment rates that applied under section 430(h)(2)(G) for plan years
beginning in 2008 or 2009.
Proposed Sec. 1.430(d)-1(f)(5)(i) and (f)(5)(ii)(A) are
substantially the same as the corresponding provisions in the existing
regulations but would make conforming edits to update the terminology
used in those provisions to conform to the terminology used in Sec.
1.411(a)(13)-1.
Proposed Sec. 1.430(d)-1(f)(5)(ii)(C) would provide that the
option under Sec. 1.430(d)-1(f)(4)(iii)(C) to substitute the
generational mortality table may be used for purposes of determining
the amount of an annuity distribution under Sec. 1.430(d)-
1(f)(5)(ii)(B). This provision is substantially the same as existing
Sec. 1.430(d)-1(f)(5)(ii)(C), except that the heading would be revised
to reflect that the option to adjust the present values to take into
account the phase-in of segment rates under section 430(h)(2)(G) is no
longer applicable.
Proposed Applicability Date
The regulations are proposed to apply to plan years beginning on or
after 6 months after the date of publication of the Treasury decision
adopting these amendments to the regulations as final regulations in
the Federal Register.
Special Analyses
I. Regulatory Planning and Review--Economic Analysis
OMB's Office of Information and Regulatory Affairs has determined
that this proposed rule is not significant and is not subject to review
under section 6(b) of Executive Order 12866, as amended. This proposed
rule is expected to be an Executive Order 14192 deregulatory action.
II. Paperwork Reduction Act
This proposed rulemaking does not impose or revise any information
collections subject to 44 U.S.C. Chapter 35.
III. Regulatory Flexibility Act
The Regulatory Flexibility Act requires consideration of the
regulatory impact on small businesses. It is hereby certified that
these proposed regulations, if adopted, will not have a significant
economic impact on a substantial number of small entities within the
meaning of section 601(6) of the Regulatory Flexibility Act (5 U.S.C.
chapter 6).
The economic impact of these regulations is not expected to be
significant. These regulations are not expected to result in
economically meaningful changes in behavior. They would update existing
regulations in order to implement statutory changes enacted after the
publication of the 2009 regulations. They provide guidance for
administrators and sponsors of single-employer defined benefit plans
regarding the determination of target normal cost and the funding
target.
For the reasons stated, a regulatory flexibility analysis under the
Regulatory Flexibility Act is not required. Notwithstanding the above,
the Treasury Department and the IRS invite comments on the impact the
proposed rules would have on small entities.
Pursuant to section 7805(f) of the Code, this notice of proposed
rulemaking will be submitted to the Chief Counsel for Advocacy of the
Small Business Administration for comment on its impact on small
business.
IV. Unfunded Mandates Reform Act
Section 202 of the Unfunded Mandates Reform Act of 1995 requires
that agencies assess anticipated costs and benefits and take certain
other actions before issuing a final rule that includes any Federal
mandate that may result in expenditures in any one year by a State,
local, or Tribal government, in the aggregate, or by the private
sector, of $100 million in 1995 dollars, updated annually for
inflation. The proposed regulations do not include any Federal mandate
that may result in expenditures by State, local, or Tribal governments,
or by the private sector in excess of that threshold.
V. Executive Order 13132: Federalism
Executive Order 13132 (entitled Federalism) prohibits an agency
from publishing any rule that has federalism implications if the rule
either imposes substantial, direct compliance costs on State and local
governments, and is not required by statute, or preempts State law,
unless the agency meets the consultation and funding requirements of
section 6 of the Executive order. The proposed regulations do not have
federalism implications, do not impose substantial direct compliance
costs on State and local governments, and do not preempt State law
within the meaning of the Executive order.
Comments and Requests for a Public Hearing
Before these proposed amendments to the final regulations are
adopted as final regulations, consideration will be given to comments
that are submitted timely to the IRS as prescribed in this preamble
under the ADDRESSES heading. The Treasury Department and the IRS
request comments on all aspects of the proposed regulations. Any
comments submitted will be made available at https://www.regulations.gov or upon request.
A public hearing will be scheduled if requested in writing by any
person who timely submits electronic or written comments. Requests for
a public hearing are also encouraged to be made electronically. If a
public hearing is scheduled, notice of the date and time
[[Page 53810]]
for the public hearing will be published in the Federal Register.
Drafting Information
The principal author of these proposed regulations is Tom Morgan of
the Office of Associate Chief Counsel (Employee Benefits, Exempt
Organizations, and Employment Taxes). However, other personnel from the
Treasury Department and the IRS participated in their development.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Proposed Amendments to the Regulations
Accordingly, the Treasury Department and IRS propose to amend 26
CFR part 1 as follows:
PART 1--INCOME TAXES
0
Paragraph 1. The authority citation for part 1 continues to read in
part as follows:
Authority: 26 U.S.C. 7805 * * *
* * * * *
Section 1.430(d)-1 is also issued under 26 U.S.C 430(g)(3)(B)
and 26 U.S.C. 430(h)(2).
* * * * *
0
Par. 2. Section 1.430(d)-1 is amended by:
0
1. Revising paragraph (b)(1)(iii)(B).
0
2. Adding paragraph (b)(1)(iii)(C).
0
3. Revising and republishing paragraphs (d)(1) and (2).
0
4. Revising paragraphs (f)(1)(ii) and
(f)(4)(iii)(C),(f)(5)(i),(f)(5)(ii)(A) and (C) and (g).
The revisions and additions read as follows:
Sec. 1.430(d)-1 Determination of target normal cost and funding
target.
* * * * *
(b) * * *
(1) * * *
(iii) * * *
(B) Plan-related expenses. For purposes of this paragraph
(b)(1)(iii), plan-related expenses consist of all amounts that are
expected to be paid from plan assets that are neither benefits paid to
participants or beneficiaries (treating the purchase of an annuity
contract as the payment of benefits) nor investment-related expenses
described in paragraph (b)(1)(iii)(C) of this section. Plan-related
expenses include fees paid for professional services (such as legal,
actuarial, and audit services), plan administration, and premiums paid
to the Pension Benefit Guaranty Corporation, among other items.
(C) Investment-related expenses. Investment-related expenses
consist of investment management fees and other expenses directly
related to the investment of the plan's assets. However, if the total
payments from plan assets to a service provider are expected to be
$5,000 or more for a plan year and consist of investment-related
expenses and expenses for other services (such as recordkeeping
services), only those amounts that the service provider itemizes as
investment management fees or other expenses directly related to the
investment of the plan's assets are treated as investment-related
expenses. Amounts itemized as expenses for other services are not
treated as investment-related expenses.
* * * * *
(d) Plan provisions taken into account--(1) General rule--(i) Plan
provisions adopted by valuation date. Except as otherwise provided in
paragraphs (d)(1)(ii) and (iii), and (d)(2) of this section, a plan's
funding target and target normal cost for a plan year are determined
based on plan provisions that are adopted no later than the valuation
date for the plan year and that take effect on or before the last day
of the plan year. For example, in the case of a plan amendment adopted
on or before the valuation date for the current plan year that has an
effective date occurring in the current plan year, the plan amendment
is taken into account in determining the funding target and the target
normal cost for the current plan year if it is permitted to take effect
under the rules of section 436(c) for the current plan year, but the
amendment is not taken into account for the current plan year if it
does not take effect until a future plan year.
(ii) Plan provisions adopted after valuation date--(A) Impact of
section 412(d)(2) election. If the plan administrator makes an election
under section 412(d)(2) with respect to a plan amendment that is
adopted no later than 2\1/2\ months after the end of a plan year, then
the amendment will be taken into account in determining the plan's
funding target and target normal cost for that plan year, provided that
the amendment takes effect no later than the date the amendment is
adopted. The preceding sentence applies even if the plan amendment is
adopted during the plan year.
(B) Impact of section 401(b)(2) election. If an employer adopts a
plan after the last day of the employer's taxable year and before the
due date for the employer's income tax return for that taxable year
(including extensions) and makes an election under the first sentence
of section 401(b)(2), then the plan is treated as adopted on the last
day of that taxable year. In such a case, the target normal cost and
funding target for the plan's first plan year are determined based on
the adopted plan provisions, provided that--
(1) The plan takes effect no later than the date the plan is
adopted; and
(2) If the plan's valuation date is before the date the plan is
treated as being adopted, a section 412(d)(2) election is made.
(C) Impact of section 401(b)(3) election. If, before the due date
(including extensions) for an employer's income tax return for a
taxable year, the employer adopts an amendment increasing benefits
accrued under a plan effective as of any date during the plan year that
immediately precedes the date of adoption, and makes an election under
section 401(b)(3) with respect to the plan amendment, then the plan
amendment is treated as having been adopted as of the last day of that
preceding plan year. In such a case, the target normal cost and funding
target for that preceding plan year are determined taking the plan
amendment into account, provided that--
(1) The amendment takes effect no later than the date it is
adopted; and
(2) If the plan's valuation date is before the date the amendment
is treated as being adopted, a section 412(d)(2) election is made.
(iii) Special rule to reflect plan operations during a remedial
amendment period--(A) Requirement to reflect future remedial amendment.
For purposes of this paragraph (d), if plan operations are changed
during a remedial amendment period (within the meaning of Sec.
1.401(b)-1(d)) to make effective a future remedial amendment, then the
provisions of the future remedial amendment are treated as adopted on
the date that the plan operations are changed. To the extent the
language of the plan's remedial amendment differs from the way the plan
was operated at any point during the remedial amendment period, the
remedial amendment is treated as adopted only when plan operations were
changed to reflect the language ultimately adopted in that amendment.
(B) Future remedial amendment. A plan makes effective a future
remedial amendment when--
(1) The plan is required to be amended to address a disqualifying
provision that has been designated as such by the Commissioner pursuant
to Sec. 1.401(b)-1(b)(3),
(2) The remedial amendment period with respect to that required
amendment has not ended, and
(3) Plan operations are changed in anticipation of a proposed
amendment
[[Page 53811]]
to the plan relating to the disqualifying provision.
(iv) Determination of when an amendment takes effect. For purposes
of this paragraph (d)(1)--
(A) The determination of whether an amendment that increases
benefits takes effect and when it takes effect is made in accordance
with the rules of section 436(c) and Sec. 1.436-1(c)(5); and
(B) In the case of an amendment that decreases benefits, the
amendment takes effect under a plan on the first date on which the
benefits of any individual who is or could be a participant or
beneficiary under the plan would be less valuable than those benefits
would be under the pre-amendment plan provisions if the individual were
on that date to satisfy the applicable conditions for the benefits.
(2) Special rule for certain amendments increasing liabilities--(i)
In general. In the case of a plan amendment that takes effect by the
last day of the plan year but is not required to be taken into account
under the rules of paragraph (d)(1) of this section because it is
adopted after the valuation date for the plan year, the plan amendment
must nonetheless be taken into account in determining a plan's funding
target and target normal cost for the plan year if the plan amendment--
(A) Increases the liabilities of the plan by reason of increases in
current benefits, establishment of new benefits, changing the rate of
benefit accrual, or changing the rate at which benefits become
nonforfeitable;
(B) Would not be permitted under section 436, as described in
paragraph (d)(2)(ii) of this section; and
(C) Disproportionately increases target normal cost, as described
in paragraph (d)(2)(iii) of this section.
(ii) Plan amendment that would not be permitted under section 436.
A plan amendment is described in this paragraph (d)(2)(ii) if the plan
amendment would not be permitted to take effect under the rules of
section 436(c) as applied under this paragraph (d)(2)(ii). The rules of
section 436(c) are applied under this paragraph (d)(2)(ii) by--
(A) Treating the increase in the target normal cost for the plan
year attributable to the amendment (and all other amendments that must
be taken into account solely because of the application of the rules in
this paragraph (d)(2)) as if the increase were an increase in the
funding target for the plan year; and
(B) Taking into account all unpredictable contingent event benefits
permitted to be paid for unpredictable contingent events that occurred
during the current plan year and all plan amendments that took effect
in the current plan year (including all amendments to which this
paragraph (d)(2) applies for the plan year).
(iii) Plan amendment resulting in disproportionate increase in
target normal cost. A plan amendment is described in this paragraph
(d)(2)(iii) if the percentage increase in target normal cost as the
result of the amendment is more than twice the percentage increase in
the funding target as a result of the amendment (taking into account
only the benefits of participants currently employed in the service of
the employer).
* * * * *
(f) * * *
(1) * * *
(ii) Changes in actuarial assumptions and funding method. Actuarial
assumptions established for a plan year cannot subsequently be changed
for that plan year unless the Secretary of the Treasury or the
Secretary's delegate (Secretary) either approves a request for a change
in actuarial assumptions that was submitted before the actuarial
assumptions were established for the plan year or determines that the
assumptions that were used are unreasonable. Similarly, a funding
method established for a plan year cannot subsequently be changed for
that plan year unless the Secretary either approves a request for a
change in funding method that was submitted before the funding method
was established for the plan year or determines that the use of that
funding method for that plan year is impermissible.
* * * * *
(4) * * *
(iii) * * *
(C) Optional application of generational mortality. In determining
the present value of a distribution under this paragraph (f)(4)(iii),
if the generational mortality tables under Sec. 1.430(h)(3)-1(b) or
Sec. 1.430(h)(3)-2 are used for a plan, then an equal-weighted blend
of the annuitant mortality rates under the Sec. 1.430(h)(3)-1(b)
generational mortality tables for males and females may be used in lieu
of the applicable mortality table under section 417(e)(3) that would
apply to a distribution with an annuity starting date occurring on the
valuation date.
* * * * *
(5) * * *
(i) In general. In the case of a statutory hybrid plan described in
Sec. 1.411(a)(13)-1(d)(5), if the amount of a future distribution is
based on an interest adjustment applied to the current accumulated
benefit, then the amount of that distribution is determined by
projecting the future interest credits or equivalent amount under the
plan's interest crediting rules using actuarial assumptions that
satisfy the requirements of paragraph (f)(3) of this section. Thus, if
a plan provides for a single sum distribution equal to the balance of a
participant's hypothetical account under a cash balance plan, then the
amount of that future distribution is equal to the projected account
balance at the expected date of payment determined using actuarial
assumptions that satisfy the requirements of paragraph (f)(3) of this
section.
(ii) * * *
(A) General rule. In the case of a statutory hybrid plan with a
lump sum-based benefit formula as described in Sec. 1.411(a)(13)-
1(d)(3), if the amount of an annuity distribution is based on either
the balance of the hypothetical account maintained for a participant or
the accumulated percentage of a participant's final average
compensation, then the amount of that annuity distribution is
calculated by converting the projected account balance (or accumulated
percentage of final average compensation), in accordance with paragraph
(f)(5)(i) of this section, to an annuity by applying the plan's annuity
conversion provisions using the rules of this paragraph (f)(5)(ii).
* * * * *
(C) Optional application of generational mortality. The option
under paragraph (f)(4)(iii)(C) of this section to substitute the
generational mortality table may be used for purposes of determining
the amount of an annuity distribution under paragraph (f)(5)(ii)(B) of
this section.
* * * * *
(g) Applicability date. This section applies to plan years
beginning on or after [DATE SIX MONTHS AFTER DATE OF PUBLICATION OF
FINAL RULE]. For earlier plan years, taxpayers may apply either the
rules of this section or the rules described in 26 CFR 1.430(d)-1 (as
it appeared in the April 1, [2026], edition of 26 CFR part 1).
Frank J. Bisignano,
Chief Executive Officer.
[FR Doc. 2026-17021 Filed 8-19-26; 8:45 am]
BILLING CODE 4831-GV-P