IRS Regulations on “Hybrid” Retirement Plans

Reprinted with permission from Employee Benefit Plan Review, April 2011. All rights reserved, WoltersKluwer Company, New York, N.Y.

Since the latter part of 2010, the Internal Revenue Service (IRS) has been active in the area of “hybrid” defined benefit pension plans, such as cash balance plans and pension equity plans (PEPs). These plans are referred to as “hybrid” plans because they are defined benefit plans that may express the accrued benefit under the plan in a manner similar to defined contribution plans, such as by reference to a hypothetical account balance. The Pension Protection Act of 2006 (PPA) revised the Internal Revenue Code (the Code) to change the way the Code’s vesting and accrual rules apply to hybrid plans.