A standardized prototype money purchase plan (calendar year) was frozen 3/31/99. The plan has the usual standardized prototype language for contribution eligibility. Is there or is there not a contribution due for 1999, and for whom? There are three categories of participants we are concerned about:

a) employed all year with 500 or more hours by 3/31/99
b) terminated with 500 or more hours before 3/31/99
c) terminated with 500 or more hours after 3/31/99 but before 12/31/99.

An argument has been made (not by me) that for people employed all year, there is a last day employment requirement and the plan was frozen before that contribution was accrued. This seems to me to defeat the purpose of a standardized prototype (no 410(B) testing).

Any thoughts?