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We are designing a new DB plan.  Company been in business for quite awhile.

Effective 2019, document signed prior to 12/31.

There is one employee that terminated in 2019 and had 692 hours.

If service for vesting was defined as service from effective date, obviously not vested, but would she get an accrual for 2019 as she worked >500 hours??

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What does the document say is the requirement for a pay credit? Is the effective date 1/1/21019?

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Yes, plan document should clearly state whether she gets an accrual or not. Regardless, she is not statutorily excluded for coverage, nondiscrimination or minimum participation purposes.

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