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What is the "Earliest Date on which benefits will becom vested"?

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ERISA Section 105 requires benefit statement to include a statement of "vested percentage of such benefits (or the earliest date on which benefits will become vested)".  Do you agree that the "earliest date" is the date on which a participant becomes partial vested?  That is, on a 2/20 vesting schedule, does a participant "become vested" when they become 20% vested or when they become 100% vested?


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Whether required or not, the benefit statement for a plan with graded vesting should disclose not only the date as of which a non-vested participant will attain partial vesting but also the date as of which a non-vested or partially vested participant will attain full vesting.  The same assumption concerning accrual of future vesting service should be used for both purposes (and why not 1 year of vesting credit for each future year on an elapsed time basis?).

Surely, such information would be useful to the participants, so why not give it to them? 

Always check with your actuary first!

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