August 19, 2020
A Cash Balance Plan is a type of retirement plan.
However, unlike individual retirement vehicles, such as IRAs, Cash Balance Plans are employer-sponsored. Thus, an individual cannot adopt a Cash Balance Plan unless he or she is self-employed. Additionally, if an individual owns a business, the entity may adopt a Plan with the owner as a participating employee.
Cash Balance Plans are Defined Benefit Plans. They are not Defined Contribution Plans (e.g., 401(k) Plans, Profit Sharing Plans, SEPs). In a Defined Benefit Plan, benefits are formulaic and specified in the Plan document. Ultimately, the employer is responsible for funding and paying promised benefits. Thus, the employer generally must make annual contributions to fund expected increases in employee retirement benefits and adjust for Plan asset returns and changes in interest rates.
Cash Balance Plans are “hybrid” Plans. Although they are Defined Benefit Plans, they have some Defined Contribution features.
For example, Cash Balance benefits are account-based. Like a 401(k) Plan, each employee’s benefit is based on an account balance. Conversely, Traditional Defined Benefit Plans are defined as lifetime monthly benefits (like Social Security).
Although Cash Balance Plans are account-based, each employee does not have their own account. Rather, the balances are tracked “on paper” but funded using a pooled Plan asset account.
A Cash Balance benefit consists of two elements: a pay credit and an interest credit.
A pay credit is the amount credited to the employee’s notional account. Pay credits can be a fixed dollar amount (e.g., $200,000 per year) or a percentage of pay (e.g., 50% of compensation).
Interest credits provide the “return” on the existing balances (prior pay and interest credits). The Plan may credit interest based on a fixed percentage (e.g., 5% per year), an index (e.g., Treasury bonds), or the return on Plan assets. Interest often is credited annually but may be credited more frequently.
The table below illustrates how a Cash Balance benefit accumulates. In this example, the employer is paying an annual pay credit of $200,000 and an interest credit of 5% at the end of each year.
|Year||Pay Credit||Interest Credit||Ending Balance|
As long as the employee remains with the employer, he or she will receive pay credits (unless the Plan is amended to curtail future pay credits). Should the employee leave the employer, pay credits no longer would be provided. However, the employer must credit the balance with interest until the benefit is paid.
A Cash Balance Plan is a powerful retirement and tax-planning vehicle for the self-employed and small business owner. For example, adopting a Plan may provide an employer with the following advantages:
With so many advantages, why would an employer not adopt a Cash Balance Plan? Here are the disadvantages of a Cash Balance Plan:
In general, yes, the employer must cover at least a portion of its employees. The IRS has provided guidelines around minimum participation, minimum coverage and nondiscrimination testing. These rules are complicated, but a competent Defined Benefit actuary can design the Plan such that the employer objectives are met while satisfying these requirements.
Yes, the employer may require employees to work at least 1,000 hours over a one-year period before participating in the Plan. The employer also may impose a minimum age requirement of up to 21 years old.
Even after employees have met the minimum age and service requirement, the Plan may further delay entry until the next January or July 1st (for a calendar year Plan). Thus, the waiting period for a full-time employee may be as long as 12 to 18 months, depending on the employee’s hire date.
Note that, alternatively, the employer may require employees to work at least 1,000 hours for two years. However, employees would need to immediately vest in their benefits after entering the Plan. More on vesting in the next section.
The employer may require an employee to work at least 1,000 hours in three years before becoming vested. Additionally, service prior to the Plan adoption or before the employee is 18 years old may be excluded.
Note that, as mentioned above, immediate vesting is required if the employer extends the eligibility period (i.e., waiting period) from one to two years. Additionally, the employee is immediately vested at the Plan’s retirement age, which generally is age 62 or 65, and upon termination of the Plan.
In some cases, the Plan will provide immediate vesting upon the employee’s death or disablement.
No, the employer can specify different pay and interest credits in the Plan document. For example, the employer may provide different formulas for hourly and salary workers, for employees at different locations, for different positions, and even for owners and non-owners.
However, because Cash Balance Plans are tax-advantaged, the coverage of employees and the allocation of benefits must pass IRS requirements. In general, these guidelines reduce the disparity between highly compensated employees (owners and highly paid employees) and everyone else.
Yes, employers may change pay credits prospectively by amending the Plan document. However, they cannot cutback existing balances. Additionally, the interest crediting basis cannot be changed without grandfathering the current basis.
Cash Balance Plans are taxed like an employer match in a 401(k) Plan. This article provides more detail.
No. Although the individual payout limit is a function of Plan compensation, employer contributions are not limited to 25% of Plan compensation. In fact, in small Cash Balance Plans, it’s not uncommon for the permissible contribution to approach, or even exceed, current compensation.
A 401(k) Plan is a Defined Contribution Plan. In these types of Plans, the amount available to the employee at retirement depends on how much is contributed, when contributions are made, and the investment returns on the contributions. There is no guarantee of what those contributions will be worth in the future.
Conversely, a Cash Balance Plan is a Defined Benefit Plan. In a Defined Benefit Plan, the employer specifies the benefit up-front then must meet the projected obligation through employer contributions and investment returns. Because Plan assets and the interest rates used to value the obligation are variable, the permissible contribution range is recalibrated each year.
Additionally, Cash Balance Plans have much higher limits than 401(k) Plans. Specifically, the annual limit for a 401(k) Plan is roughly $60,000 per year, while the Cash Balance limit can be as high as several hundred thousand dollars per year.
Both Cash Balance Plans and Traditional Defined Benefit Plans are types of Defined Benefit Plans.
In many respects, small employers can achieve similar results with either type of arrangement. However, there are differences:
Yes, it is common for employers to adopt a 401(k) Plan in addition to their Cash Balance Plan. This is called a Cash Balance / 401(k) Combo Plan.
For owner-only or owner and spouse businesses, adding a 401(k) increases potential tax deductions. For businesses with non-owner employees, adopting a 401(k) Plan generally reduces the cost of passing nondiscrimination testing (i.e., lowers the cost of employee retirement benefits).
Like other employer-sponsored retirement Plans, Cash Balance Plans require compliance with the applicable laws and regulations.
For example, Cash Balance Plans must have a written Plan document and have Plan assets held in trust. Generally, the employer must make annual contributions to the Plan. Additionally, the Form 5500 must be filed annually once Plan assets exceed $250,000.
If the business has non-owner employees, the employer also must provide its employees required disclosures, be bonded, and pass coverage and nondiscrimination requirements. Additionally, if the Plan is covered by the PBGC, the employer must submit filings and pay corresponding premiums annually.
In most cases, employees direct the employer to pay their account balances as a single sum distribution. However, the employer also must provide the employee with lifetime payment options.
These lifetime options generally include a monthly annuity payable for the employee’s lifetime and a spousal option that provides a benefit payable for the spouse’s lifetime should the employee die first.
The conversion between the account balance and the optional forms is done using the Plan’s definition of actuarial equivalence.
The Cash Balance payout limit is a function of both age and historical compensation. At age 62, for example, the payout can be as high as roughly $3.2 million per person! Thus, in an owner and spouse Plan, the total maximum payout may be as high as roughly $6.4 million.
This article provides a table showing how the maximum payout is adjusted by age.
It is worth exploring a Cash Balance Plan if you are self-employed or own a business, are at least 35 years old, and your contribution is being limited by your existing retirement Plan.
Although there are other factors to consider, an actuary specializing in Defined Benefit and Cash Balance Plans, can help you understand if a Cash Balance Plan is right for you.
The first step is to talk with a Defined Benefit and Cash Balance Plan specialist. Typically, this will be an actuary but also could be a third party administrator who outsources the certification of its figures to an actuary.