Can a new plan use the 5-year phase in for the 417(e) interest rates? Participants will be 100% vested immediately in the new plan, so there will be lump sums paid during the first five years.

Are those all that are being published?

How will you satisfy 436 so that lump sums can be distributed?

Your plan document could provide an interest rate and mortality in its definition that could provide higher lump sums (if you wanted) as long as they did not exceed the 415 limit.

Otherwise, the true minimum is the phased-in kind: you are required to use the 80% of GATT and 20% of the new segmented rate structure for determining the minimum for 2008. Based on current interest rates, you would not satisfy 417(e) by paying a lump sum based 0% of the GATT rate and 100% of the new segmented rates, you'll have to wait until 2012 for that.

That being said, you are required to fund using the segmented rates (100%). But lump sum amounts will be based on the 80% GATT / 20% segmented rates. Hmmm. That appears to support the underfunding of a new plan until 2012. Was that what they were hoping for under the new funding rules?

Are you guys suggestimg that for S417 lump sum, we have to compute segment rates ourselves using the formula:
x% of S417 segment rates + (1-x%) of 30 year Treasury rates published by the IRS?

I thought the S417(e) segment rates published by the IRS for PYs after 2007 are the "phased in rates" and those are supposed to be used without any additional adjustment!

Think the IRS has them both out, but you have to be careful w/ noncalendar year plans going forward if you just reference the issued blended rates.