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Title:  

Article 3 and 4 Pension Plans as They Relate to Social Security Replacement Plan Rules and Guidance for Comparability Testing

 
 Volume/Number:  2024 June 4 
 Issuing Agency:   
 Description:  COGFAs actuary provides an analysis of Article 3 and Article 4 pension funds relating to satisfying the Internal Revenue Code Safe Harbor provision that allows a public sector pension plan to operate independently of Social Security, or as a Social Security Replacement Plan. The analysis concludes that that because of the Tier 2 accrual formula and pensionable salary calculation, Downstate Police and Fire pension funds generally satisfy the Safe Harbor provision. The actuary notes that some plans may fall out of compliance decades into the future, particularly those funds whose salary characteristics skew heavily towards the higher end of the earnings spectrum. In cases where non-compliance with the Safe Harbor provision is at issue, individual testing at the local level would be required. 
 Date Created:  06-04-2024 
 Agency ID:   
 ISL ID:  000000107215   Original UID: 213838 FIRST WORD: Article