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Proposed Regulations Regarding Hybrid Defined Benefit Plans Offer Transition Relief

As discussed above, the final regulations provided additional guidance on the requirement that a hybrid defined benefit plan not provide for interest credits at an effective rate that is greater than a market rate of return. Proposed regulations were also issued that permit a hybrid defined benefit plan that does not currently satisfy this requirement to satisfy the requirement by changing the specific portions of interest crediting rates that are not consistent with the final regulations to permitted interest crediting rates without violating the anti-cutback rules under ERISA. Comments on the proposed regulations must be received by December 18, 2014, and a public hearing is scheduled for January 9, 2015.?á The proposed regulations can be found?áhere.

The lawyers of our Employee Benefits and Executive Compensation Practice Group are readily able to assist companies on a nationwide basis with implementing sophisticated benefit plans and providing answers to their most challenging compensation issues. Additionally, our lawyers are well aware of the daily employee benefits challenges facing companies of all sizes and are capable of helping in-house lawyers and human resources personnel with the day-to-day advice and guidance necessary to properly administer employee benefits plans.

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