The Internal Revenue Service (IRS) has revealed proposed regulations regarding mortality tables to be used by most defined benefit (DB) pension plans. These tables gage the probability of survival year-by-year for an individual based on age, gender, and other factors. This data along with actuarial assumptions is used to calculate the present value of a stream of expected future benefit payments, for purposes of determining the minimum funding requirements for a plan. These mortality tables also can be used to determine the minimum required amount of a lump-sum distribution from such a plan.
“The proposed regulations would update the mortality tables used to determine minimum required contributions for single-employer plans and current liability for multiemployer plans effective for plan years beginning in 2018,” explains Scott A. Hittner, FSA, partner and chief actuary at October Three. “The base mortality table would be updated from the RP-2000 table to the RP-2014 table. Projected mortality improvements would be based on the MP-2016 scale, updated from Scale AA.”
The IRS also unveiled proposed regulations to update the requirements that a plan sponsor must meet in order to obtain IRS approval to use mortality tables specific to the plan for minimum funding purposes, instead of the generally applicable mortality tables.
“As under current rules, plans would be allowed to use either a generational table or separate static annuitant and nonannuitant tables, and small plans (those covering no more than 500 participants) would be permitted to use a combined annuitant/nonannuitant static table,” says Hittner.
He explains that the methodology used to develop static tables would be tweaked to vary the projection by age and gender. For purposes of updating mortality improvement rates after 2018, the IRS and Treasury expect to consider the anticipated annual updates from the SOA’s Retirement Plans Experience Committee (RPEC).
“In accordance with the changes made by the Bipartisan Budget Act of 2015, the proposed regulations would make substantial changes to the rules on using substitute mortality tables for determining single-employer minimum funding requirements,” says Hittner. “The changes would generally simplify the construction of experience-based substitute mortality tables and allow smaller plans not having “fully credible” mortality data to use a weighted average of the standard mortality table and the experience-based substitute mortality table that would result if the plan had fully credible data. Small plans not having at least 100 deaths for a gender (substitute mortality tables are by gender, and if one gender doesn’t have credible experience, the standard table is used for that gender) over a five-year period are not permitted to use a substitute mortality table. In order to use a substitute mortality table, a sponsor would need IRS’ approval.”
Hittner adds, “The updated standard mortality tables may increase liabilities approximately 5%. However, the impact will vary from plan to plan and might be highest for retiree-heavy plans. Note that there should be no significant impact on cash balance plans.”
A document outlining these proposals can be found here.