Originally Posted by
Longhornmaniac8
I've seen some concerning communications from people I would expect to know the details on these things that the cap on company contributions to the PRAP, which has been the sticking point for most of us, will be there irrespective of the passage or rejection of this LOA (once the MBCBP is implemented, that is).
This feels to me like an unintended consequence that, truthfully, derails the benefits we receive from it. Ultimately, it's a dollars and cents decision, but to say I'm disappointed in that (if true) is an understatement.
it is true that the only way the company will implement the CPB is with the reduced company contributions cap… regardless of the out time of this LOA.. which h means if the LOA doesn’t pass, there will be no CBP .. unless..
not only does will there need to be a favorable determination letter from the IRS for the CBP , but we will also need to request a PLR (private letter ruling) on the contingent benefit rule on the PRAP. A favorable determination letter for the CPB only means that they are approving our plan, not that there is not a conflict with other plans.
The contingent benefit rule is a PRAP (401k) problme and therefore a separate PLR is necessary from the IRS to re-evaluate the PRAP with the new CBP.. however (strangely) they are under no obligation to respond or issue a PLR.