MMC Benefits Handbook
409A BEP Benefit Small Benefit Payment Rule
If you separate from service due to a reduction in hours or a bona fide unpaid leave of absence longer than six months, your 409A BEP Benefit will be aggregated with all 409A benefit amounts payable from all similar plans that you might have participated in, including but not limited to the Supplemental Retirement Plan, the Johnson & Higgins Supplementary Retirement, the Sedgwick Excess Plan, or the ORC Excess Plan, when evaluating whether your 409A benefits are a small benefit. Generally, your 409A benefit will be evaluated under the small benefit rule as of the first of the month following the calendar month in which you separate from service.
If your 409A benefit is determined to be a small benefit, you will receive a single sum payment representing your entire vested accrued benefit under the Plan, the single sum payment amount will be determined as of the first of the month following the calendar month in which you separate from service and payment will be made in the fourth month (seventh month if you are a Specified Employee) following the calendar month in which you separate from service.
In the event that you die after your Separation from Service but before you receive your single sum payment, the single sum payment will be made to your Designated Survivor. If you do not have a Designated Survivor, the single sum will be paid to your Spouse or Domestic Partner as the case may be. If you do not have a Spouse or Domestic Partner, the single sum will be paid to your estate.
If you have a disability separation, your 409A benefit will be evaluated under the small benefit rule as of the first of the month following the earlier of (i) the month in which you attain age 65 or (ii) the month your eligibility for a benefit under the MMC Long Term Disability Plan ends. Payment will be made as soon as practicable, but in no event more than 90 days later.
For a description of the small benefits payment rule that applies in the event of your death, see 409A Survivor Benefit If You Die While Actively Employed" for details.
If you accrued a Grandfathered BEP Benefit prior to January 1, 2005 different rules apply. See "Small Benefit Payment Rule for Grandfathered BEP Benefit" for details.
A 409A BEP Benefit is considered to be a small benefit if the aggregate single sum value of the benefit accruals attributable to the BEP, the SRP, the J&H Excess Plan, the Sedgwick Excess Plan, the ORC Excess Plan and all similar non-qualified plans that are subject to Section 409A, less any portion of the benefit that has already been paid is less than the IRS prescribed limit ($18,000 for 2015) assuming payment of those accrued benefits occurs at the later of your earliest retirement age under each plan or your Separation from Service date.
For example, suppose Dave had a Separation from Service at age 65 on July 1, 2014. Let's assume he had accrued a 409A benefit of $40.00 in the BEP and $70.00 in the SRP. Dave's aggregate monthly 409A benefit is $110 ($40 BEP + $70 SRP) and is expressed as a single life annuity. The single sum value of the aggregate monthly benefit of $110, calculated using a current interest rates and a current mortality table is approximately $14,500. Since this is less than the threshold amount of $18,000, it is considered a small benefit and Dave would receive a single sum of $14,500. He would not have the option of receiving his 409A benefit as an annuity.
Because the BEP is not a Tax-Qualified Plan, a single sum distribution of a small benefit cannot be rolled over to an IRA or other retirement plan eligible to receive rollovers.