Human Resources
Aon Hewitt Submits Comments on Hybrid Retirement Plans

Aon Hewitt Submits Comments on Hybrid Retirement Plans


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On December 17, 2014, Aon Hewitt submitted comments to the Internal Revenue Service (IRS) on the proposed regulations on hybrid defined benefit plans. The IRS published the proposed regulations in the Federal Register on September 19, 2014.

In comments to the IRS, Aon Hewitt responds to the four questions posed to respondents in the preamble to the proposed regulations regarding plans that credit interest using an investment-based rate of return with an impermissible minimum annual or more frequent fixed or variable minimum rate. Aon Hewitt then discusses additional areas of concern regarding the proposed regulations, including:

  • Interest crediting rates not satisfying timing rules;
  • Interest crediting rates that must be limited to third corporate bond segment rate;
  • Noncompliant cumulative minimum interest crediting rates;
  • Greater of two or more variable investment-based interest crediting rates; and
  • Pension equity plans with implicit interest crediting rates.

The Aon Hewitt comment letter was authored by Eric Keener (Retirement) and Dan Schwallie (Retirement).

Aon Hewitt Submits Comments on Hybrid Retirement Plans

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