De-risking a Defined Benefit Pension Plan? The IRS Ixnayed One Option

October 8, 2015 | Authored by Brendan P. Brady CPA, CVA


October 8, 2015 – As sponsors of defined-benefit pension plans look to reduce risks associated with volatile stock markets and an aging but increasingly long-lived workforce, one strategy that has attracted particular attention in recent years is de-risking of those plans. Simply put, de-risking is a process by which companies seek to reduce or eliminate potential volatility in future pension plan contributions in order to better predict and manage cash flows and improve profitability. There are a number of de-risking strategies available to plan sponsors, ranging from liability redesign (for example, closing plan to new participants), to investment strategies (for example, utilization of dynamic asset allocation strategies), to liability transfer (for example, annuity purchases).

One de-risking strategy that has been popular with sponsors of defined benefit plans is the use of lump sum pay-outs. This strategy involves the payment of a single lump sum benefit to retirees or their beneficiaries currently being paid with an annuity payment. The Internal Revenue Service (IRS), however, has effectively put an end to this practice with Notice 2015-49, which prohibits defined benefit plans from replacing current annuity payments with lump sum pay-outs or other accelerated forms of distributions. The amendment to the Internal Revenue Code described in this Notice was effective as of July 9, 2015; however, lump-sum offers authorized before that date or for which Plan sponsors received a private letter ruling before that date will not be affected.

While the IRS’ recent action does eliminate one valuable de-risking option for Plan Sponsors, several other methods for mitigating the economic and demographic risks associated with sponsoring a defined-benefit pension plan do remain available, including plan design changes and investment policy changes. For more information, please contact Brendan Brady at, a member of our Employee Benefits Plan Team or Chad O’Connell at if you would like further information.

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About the Author

Brendan P. Brady CPA, CVA

Brendan is responsible for managing client engagements, team scheduling, training and development. He leads general and specialized audits as well as internal control projects, and is one of the leaders of the Firm’s employee benefit plan audit practice. He uses his experience to offer management advice and suggestions for improving operational efficiency by obtaining a thorough understanding of a business, not just from the controller’s standpoint, but from management’s and the operational side.

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