Beg. 1/1/2000 all plans must comply w/ the 417(e)(3) Gatt requirements. If a plan has yet to actually amend the plan do they just comply w/ Gatt operationally or do they still grandfather the PBGC rates as well as applying the GATT rates? Or does anyone have other thoughts?

I'll try to summarize and hope I get it right. Begininng with the first day of the 2000 plan year, 417(e)(3) is modified to provide a different set of assumptions that must serve as the minimum for a lump sum distribution. If the plan is not yet amended, the amendment period has been extended to end of the 2000 plan year, but the amendment must be retroactive to beginning of plan year.

However, the lump sum minimum must be the greater of the old (PBGC) minimum, or the new (GATT) minimum. This "greater of" applies to any lump sum payments made from the first day of the 2000 plan year to the actual date of adoption of the amendment.