rr-01-62.pdf

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Part I
Section 417. -- Definitions and Special Rules For Purposes of Minimum Survivor Annuity
Requirements
26 CFR 1.417(e)-1: Restrictions and valuations of distributions from plans subject to sections
401(a)(11) and 417.
(Also, § 415.)
Rev. Rul. 2001-62
ISSUE
What mortality table is the prescribed table under § 415(b)(2)(E)(v) of the Internal Revenue
Code (the “Code”) and the applicable mortality table under § 417(e)(3)(A)(ii)(I)?
LAW AND ANALYSIS
Section 415(b) provides for limitations on benefits payable under qualified defined benefit
plans. Section 415(b)(1) provides, for limitation years ending on or before December 31, 2001, that
the limitation on benefits, when expressed as an annual benefit (i.e., a benefit payable annually in
the form of a straight life annuity with no ancillary benefits) is the lesser of (a) $90,000 (as adjusted
for increases in the cost of living) or (b) 100 percent of the participant's average compensation for
the high 3 years. Section 415(b)(2)(B) provides that, if the benefit under the plan is payable in any
form other than a straight life annuity, the determination of whether the limitation of § 415(b)(1) has
been satisfied is made by adjusting such benefit so that it is equivalent to a straight life annuity.
Sections 415(b)(2)(C) and (D) provide, for limitation years ending on or before December 31, 2001,
for adjustments to the $90,000 (as adjusted for increases in the cost of living) limit when benefits
begin at an age other than at social security retirement age.
For limitation years ending after December 31, 2001, section 611(a) of the Economic
Growth and Tax Relief Reconciliation Act of 2001, Public Law 107-16 (EGTRRA), made a number
of changes to the limitations under § 415 of the Code. For limitation years ending after December
31, 2001, the adjustments under § 415(b)(2)(C) apply to benefits that commence before age 62
and the adjustments under § 415(b)(2)(D) apply to benefits that begin after age 65.
Section 415(b)(2)(E)(v) provides that, for purposes of adjusting any benefit or limitation
under § 415(b)(2)(B), (C), or (D), the mortality table used is the table prescribed by the Secretary.
The statute further provides that the table is based on the prevailing commissioners' standard table
(described in § 807(d)(5)(A)) used to determine reserves for group annuity contracts issued on the
date the adjustment is being made (without regard to any other subparagraph of § 807(d)(5)).
Section 417(e)(3) provides rules for the determination of the present value of plan benefits
for purposes of § 417(e). Section 417(e)(3)(A)(i) generally provides that, for purposes of

2
§ 417(e)(1) and (e)(2), the present value is not less than the present value calculated by using the
applicable mortality table and the applicable interest rate. In addition, § 411(a)(11)(B) provides
that, the determination of present value for purposes of § 411(a)(11)(A) is calculated in accordance
with § 417(e)(3). Sections 203(e)(1), 203(e)(2), and 205(g)(3) of the Employee Retirement Income
Security Act of 1974 (ERISA) provide corresponding provisions to §§ 411(a)(11)(A), 411(a)(11)(B),
and 417(e)(3) of the Code.
Section 417(e)(3)(A)(ii)(I) defines the term "applicable mortality table" as the mortality table
prescribed by the Secretary. The statute further provides that the table is based on the prevailing
commissioners' standard table (described in § 807(d)(5)(A)) used to determine reserves for group
annuity contracts issued on the date the adjustment is being made (without regard to any other
subparagraph of § 807(d)(5)).
Section 1.417(e)-1(d)(1) of the Income Tax Regulations provides that a defined benefit plan
must provide that the present value of any accrued benefit and the amount (subject to §§ 411(c)(3)
and 415) of any distribution, including a single sum, must not be less than the amount calculated
using the applicable interest rate described in § 1.417(e)-1(d)(3) (determined for the month
described in § 1.417(e)-1(d)(4)) and the applicable mortality table described in § 1.417(e)-1(d)(2).
The present value of any optional form of benefit cannot be less than the present value of the
normal retirement benefit determined in accordance with the preceding sentence. Under
§ 1.417(e)-1(d)(1), these rules must also be used to compute the present value of the benefit for
purposes of determining whether consent for a distribution is required.
Section 1.417(e)-1(d)(2) provides that the applicable mortality table is the mortality table
based on the prevailing commissioners' standard table (described in § 807(d)(5)(A)) used to
determine reserves for group annuity contracts issued on the date as of which present value is
being determined (without regard to any other subparagraph of § 807(d)(5)), that is prescribed by
the Commissioner in revenue rulings, notices, or other guidance published in the Internal Revenue
Bulletin. The Commissioner may also prescribe rules that apply in the case of a change to the
prevailing commissioners’ standard table.
For purposes of § 807(d)(5) of the Code, Rev. Rul. 92-19, 1992-1 C.B. 227, sets forth the
prevailing commissioners' standard table for group annuities as the 1983 Group Annuity Mortality
Table (83 GAM) for contracts issued after January 1, 1985.
The U.S. Supreme Court, in Arizona v. Norris, 463 U.S. 1073, 1084-1086 (1983), held that
the application of sex-distinct actuarial tables to employees based upon their gender in calculating
the amount of retirement benefits violates Title VII of the Civil Rights Act of 1964.
Rev. Rul. 95-6, 1995-1 C.B. 80, provided a mortality table, based upon a fixed blend of 50
percent of the male mortality rates and 50 percent of the female mortality rates from the 83 GAM,
as the applicable mortality table for purposes of adjusting benefits or limitations under § 415(b)(2)
of the Code and determining the present value of plan benefits under § 417(e)(3). Rev. Rul. 98-1,
1998-1 C.B. 249, Q & A-6, provides that Rev. Rul. 95-6, provides the mortality table which
generally must be used for the purposes of adjusting any benefit or limitation under
§§ 415(b)(2)(B), (C), or (D).
For purposes of § 807(d)(5) of the Code, Rev. Rul. 2001-38, 2001-33 I.R.B 124,
supplements Rev. Rul. 92-19 by setting forth, for certain insurance products issued on or after
January 1, 1999, the prevailing commissioners' standard table for group annuities as the 1994
Group Annuity Reserving Table (94 GAR).

3
Section 411(d)(6) of the Code generally prohibits a plan amendment that decreases a
participant’s accrued benefit. Section 411(d)(6)(B) provides that an amendment that eliminates an
optional form of benefit is treated as reducing a participant’s accrued benefit, but permits the
Secretary of Treasury to provide for the elimination of certain optional forms of benefits under
regulations. Section 1.411(d)-4, Q & A-2(b) provides that the Commissioner may, through the
publication of revenue rulings, notices and other items of general applicability, provide for the
elimination or reduction of certain § 411(d)(6) protected benefits that have already accrued.
Section 401(b) and the regulations thereunder provide a remedial amendment period during
which an amendment to a disqualifying provision may be made retroactively effective, under
certain circumstances, to comply with the requirements of § 401(a). In Notice 2001-42, 2001-30
I.R.B. 70, the Service provided that the remedial amendment period for changes in the plan
qualification requirements made by EGTRRA would end no earlier than the end of the first plan
year beginning on or after January 1, 2005. This "EGTRRA remedial amendment period" is
available only if good faith EGTRRA plan amendments have been adopted by, generally, the end
of the first plan year beginning on or after January 1, 2002.
HOLDING
The following mortality table, based upon a fixed blend of 50 percent of the unloaded male
mortality rates and 50 percent of the unloaded female mortality rates underlying the mortality rates
in the 94 GAR, projected to 2002, is the applicable mortality table for purposes of adjusting benefits
or limitations under § 415(b)(2) of the Code and for determining the present value of plan benefits
under § 417(e)(3) and the corresponding provisions of ERISA. The table shows, for each age, the
number living based upon a starting population of one million lives at age 1 (l
x
), and the annual rate
of mortality (q
x
).
Plans may incorporate this table by reference to this revenue ruling. A plan amendment will
not violate section § 411(d)(6)(B) of the Code and the corresponding provision of ERISA solely
because of a reduction in any annuity distribution with an annuity starting date on or after the later
of the adoption date or the effective date of this amendment if the cause of such reduction is the
substitution of the table in this revenue ruling for the table in Rev. Rul. 95-6. If the effective date is
earlier than the adoption date of this plan amendment, § 415(b)(2)(B) of the Code will not be
violated if such amendment provides that any payments made after the adoption date will be
reduced actuarially by the value of the excess, if any, of annuity distributions paid before the
adoption date of this amendment over annuity distributions that would have been permissible
under section § 415(b)(2)(B) if the amendment had been adopted as of such effective date.
Mortality Table
for sections 415 and 417(e)
Agelxqx
11000000.00.000514
2999486.000.000341
3999145.180.000270
4998875.410.000207
5998668.640.000188
6998480.890.000179
7998302.160.000170
8998132.450.000154

4
9997978.740.000148
10997831.040.000150
11997681.370.000158
12997523.740.000171
13997353.160.000192
14997161.670.000225
15996937.310.000262
16996676.110.000296
17996381.090.000324
18996058.260.000343
19995716.610.000357
20995361.140.000368
21994994.850.000381
22994615.760.000396
23994221.890.000418
24993806.310.000441
25993368.040.000468
26992903.140.000500
27992406.690.000523
28991887.660.000543
29991349.070.000564
30990789.950.000588
31990207.370.000612
32989601.360.000633
33988974.940.000649
34988333.100.000661
35987679.810.000675
36987013.130.000695
37986327.160.000727
38985610.100.000768
39984853.150.000819
40984046.560.000879
41983181.580.000944
42982253.460.001014
43981257.450.001083
44980194.750.001151
45979066.550.001224
46977868.170.001312
47976585.210.001422
48975196.510.001554
49973681.050.001699
50972026.770.001869
51970210.050.002065
52968206.570.002302
53965977.760.002571
54963494.230.002854
55960744.420.003197
56957672.920.003614
57954211.890.004124
58950276.720.004712
59945799.020.005345

5
60940743.720.006062
61935040.930.006912
62928577.930.007846
63921292.310.008958
64913039.370.010151
65903771.110.011441
66893431.060.012870
67881932.600.014291
68869328.900.015614
69855755.200.017000
70841207.360.018396
71825732.510.020025
72809197.220.022026
73791373.840.024187
74772232.880.026581
75751706.160.029310
76729673.650.032392
77706038.060.036288
78680417.350.040636
79652767.910.045463
80623091.120.050795
81591441.210.056655
82557933.110.063064
83522747.620.069481
84486426.590.076539
85449195.990.084129
86411405.580.092686
87373274.040.103014
88334821.590.114434
89296506.620.126925
90258872.520.140650
91222462.100.154664
92188055.220.170190
93156050.100.186631
94126926.310.203518
95101094.520.222123
9678639.100.240233
9759747.390.259380
9844250.110.278936
9931907.160.297614
10022411.140.316630
10115315.100.338758
10210126.990.358830
1036493.120.380735
1044020.960.404426
1052394.780.427883
1061370.090.449085
107754.800.466012
108403.050.478582
109210.160.488140
110107.570.494813

6
11154.340.498724
11227.240.500000
11313.620.500000
1146.810.500000
1153.410.500000
1161.710.500000
1170.860.500000
1180.430.500000
1190.220.500000
1200.111.000000
EFFECTIVE DATE
The required use of the mortality table in this revenue ruling is effective for distributions with
annuity starting dates on or after December 31, 2002, except that a plan may specify any earlier
date during calendar year 2002 as the effective date for the required use of the mortality table in
this revenue ruling under the plan. The effective date for the required use of the mortality table set
forth in this revenue ruling for a plan is referred to as the plan’s 94 GAR effective date. A plan’s 94
GAR effective date must apply uniformly for purposes of §§ 415 and 417(e) of the Code and §
205(g)(3) of ERISA.
PLAN AMENDMENT
The latest date by which a plan may be amended to comply with this revenue ruling is the
last day of the plan year that contains the plan’s 94 GAR effective date. Thus, a plan with a July 1
to June 30 fiscal plan year ending June 30, 2002, must be amended no later than June 30, 2002, if
the effective date is between January 1, 2002, and June 30, 2002. If such a plan is amended
during its July 1, 2002, to June 30, 2003, plan year, the plan’s 94 GAR effective date may be no
earlier than July 1, 2002.
For a plan amendment adopted to comply with this revenue ruling no later than the last day
of the plan year that contains the plan’s 94 GAR effective date, the remedial amendment period
under § 401(b) will end at the end of the EGTRRA remedial amendment period.
DETERMINATION LETTERS
Determination letter applications filed on or after the last day of the plan year that contains
the plan’s 94 GAR effective date will be reviewed with respect to whether the form of the plan
satisfies the requirements of this revenue ruling. Determination letter applications filed before the
last day of the plan year that contains the plan’s 94 GAR effective date will be reviewed with
respect to whether the form of the plan satisfies the requirements of this revenue ruling if an
amendment to comply with the ruling is submitted with the request for the determination letter. In
either case, determination letters issued with respect to such applications may be relied on with
respect to the requirements of this revenue ruling.
MODEL PLAN AMENDMENTS
The Appendix provides two alternative model plan amendments that a plan sponsor, or a
sponsor of a pre-approved plan, may adopt to comply with this revenue ruling. The first model
amendment is intended to have the effect of adopting the mortality table set forth in this revenue

7
ruling for purposes of adjusting any benefit or limitation under § 415(b)(2)(B), (C), or (D) and the
applicable mortality table used for purposes of satisfying the requirements of § 417(e). The second
model amendment is intended to have the effect of substituting the mortality table set forth in this
revenue ruling for the mortality table set forth in Rev. Rul. 95-6 for all purposes under the plan for
which the use of the mortality table set forth in Rev. Rul. 95-6 is specified. A plan sponsor should
consider which of these two approaches is appropriate for the particular plan, or whether some
other approach should be chosen for the plan.
A pre-approved plan (that is, a master or prototype or volume submitter plan) may be
amended by the document’s sponsor to comply with this revenue ruling to the extent authorized.
Alternatively, adopting employers may adopt a plan amendment as an addendum to the plan or
adoption agreement. The inclusion of either of the model plan amendments below in an addendum
to a plan adopted to comply with EGTRRA will not cause a pre-approved plan to be treated as an
individually designed plan,
A plan sponsor that adopts either of the model amendments verbatim (or with only minor
changes) will have reliance that the form of its plan satisfies the requirements of this revenue
ruling, and the adoption of such an amendment will not adversely affect the plan sponsor’s reliance
on a favorable determination, opinion or advisory letter.
EFFECT ON OTHER DOCUMENTS
Rev. Rul. 95-6 is superseded for distributions with annuity starting dates on or after the
earlier of December 31, 2002, or the date specified in the plan for which the use of the mortality
table set forth in this revenue ruling is specified (which may be no earlier than January 1, 2002).
Rev. Rul. 98-1 is modified.
COMMENTS REQUESTED
The 94 GAR is designed as a generational table that incorporates mortality improvements
on an annual basis. The table in this revenue ruling is based on the 94 GAR projected, using Scale
AA, to 2002. Comments are requested in regard to how often the mortality table for §§ 415 and
417(e) of the Code should be updated. Comments should be sent to Commissioner of Internal
Revenue Service, Attention T:EP:RA:T:A1, Washington D.C. 20224.
DRAFTING INFORMATION
The principal author of this revenue ruling is Lawrence Isaacs of Employee Plans, Tax
Exempt and Government Entities Division. For further information regarding this revenue ruling,
please contact the Employee Plans’ taxpayer assistance telephone service at 1-877-829-5500
between the hours of 8:00 a.m. and 9:30 p.m. Eastern time, Monday through Friday (a toll-free
number). Mr. Isaacs may be reached at 1-202-283-9710 (not a toll free number).

8
Appendix – MODEL AMENDMENTS
The following are amendments that sponsors of qualified defined benefit plans may adopt
to comply with §§ 415 and 417(e), as required under Rev. Rul. 2001-62.
MODEL PLAN AMENDMENT 1
1. Effective date. This section shall apply to distributions with annuity starting dates on or after
_________.
2. Notwithstanding any other plan provisions to the contrary, the applicable mortality table used for
purposes of adjusting any benefit or limitation under § 415(b)(2)(B), (C), or (D) of the Internal
Revenue Code as set forth in section _______ of the plan and the applicable mortality table
used for purposes of satisfying the requirements of § 417(e) of the Internal Revenue Code as
set forth in section _______ of the plan is the table prescribed in Rev. Rul. 2001-62.
3. For any distribution with an annuity starting date on or after the effective date of this section and
before the adoption date of this section, if application of the amendment as of the annuity
starting date would have caused a reduction in the amount of any distribution, such reduction is
not reflected in any payment made before the adoption date of this section. However, the
amount of any such reduction that is required under § 415(b)(2)(B) must be reflected actuarially
over any remaining payments to the participant.
Note: This amendment should be used for plans that reference the applicable mortality table only
for the purposes of adjusting any benefit or limitation under § 415(b)(2)(B), (C), or (D) of the
Internal Revenue Code and satisfying the requirements of § 417(e) of the Internal Revenue
Code. Paragraph 3 of this amendment should be used only if the effective date of the
amendment is earlier than the adoption date of the amendment.
MODEL PLAN AMENDMENT 2
1. Effective date. This section shall apply to distributions with annuity starting dates on or after
_________.
2. Notwithstanding any other plan provisions to the contrary, any reference in the plan to the
mortality table prescribed in Rev. Rul. 95-6 shall be construed as a reference to the mortality
table prescribed in Rev. Rul. 2001-62 for all purposes under the plan.
3. For any distribution with an annuity starting date on or after the effective date of this section and
before the adoption date of this section, if application of the amendment as of the annuity
starting date would have caused a reduction in the amount of any distribution, such reduction is
not reflected in any payment made before the adoption date of this section. However, the
amount of any such reduction that is required under § 415(b)(2)(B) must be reflected actuarially
over any remaining payments to the participant.

9
Note: This amendment should be used for plans that specifically reference the mortality table
provided in Rev. Rul. 95-6 and apply that table for other purposes as well as for purposes of
adjusting any benefit or limitation under § 415(b)(2)(B), (C), or (D) and satisfying the
requirements of § 417(e), where the plan sponsor wishes to replace the mortality table
provided in Rev. Rul. 95-6 with the mortality table provided in Rev. Rul. 2001-62 for all
purposes. If the plan references the mortality table prescribed in Rev. Rul. 95-6 using some
other label (such as, for example, the GAM 83 blended mortality table), the plan’s term
should be used in place of the reference to the mortality table prescribed in Rev. Rul. 95-6.
Paragraph 3 of this amendment should be used only if the effective date of the amendment
is earlier than the adoption date of the amendment.