I just received the pamphlet for the Corbel Advanced Pension Conference and one of the topics is "QNEC Creativitity after the New Regulations". I also heard at an ASPA conference that the IRS was doing away with bottom up QNECS. Have I missed a regulation? Do I need to be concerenced using bottom ups for 2002? Does anyone know where the new regs are? If so, please help. Thanks

The regs are still being worked on. They were supposed to be issued by now, but continue to get delayed. I do not think they have reached the "sign-off" stage yet where it goes around for a couple of weeks being signed off on by everyone who cares.

These are omnibus 401(k) regs, not just targeted at some particular issues. They will bring together every guidance that has been issued on 401(k) in the past.

IRS & Treasury representatives have repeatedly said that the new regs would outlaw bottom-up QNECs, but the actual language of how they will accomplish this has not been released.