I understand that GATT does not apply for purposes of calculating benefit payments, but does it apply for purposes of valuing benefits under Code sec. 415?:confused:

I believe that it does. And in my experience, a great many governmental plans are not aware of the subtleties of 415--they just figure that if the annual benefit does not exceed the amount set forth in the statute, they are okay. However, in many instances a plan will provide for a lump sum (e.g., of a DROP benefit), the return to a survivor of employee (after-tax or picked up) contributions, or other features that would require the adjustment of the 415(B) amount.

Thanks for your reply - also for the summary of government requirements on your website, which was very helpful.