jkharvey Posted May 10, 2022 Share Posted May 10, 2022 We have a 401k/PS plan that provided 100% vesting for Employer discretionary PS contributions. When we prepared the cycle 3 restatement, we included a change in that vesting schedule making it 2-6 graded. The restatement was effective 1/1/2021 and the employer signed it 4/15/2021. Eligibility requirements are 1 yos/21 yoa and 1/1 7/1 entry dates. One employee hired 1/21/2020, so met eligibility at 1/21/2021 and entered the plan 7/1/2021. Does this participant have to be 100% vested following the pre amendment provision or is he subject to the amended graded schedule since he did not become a Participant until after the later of the restatement's effective date or adoption date? The plan document makes reference to an Employee who is a Participant as of the later of the date such amendment is adopted or the date it becomes effective being required to have his Vested interest as of such date not less than it would have been without regard to such amendment. Thank you Link to comment Share on other sites More sharing options...
Bri Posted May 11, 2022 Share Posted May 11, 2022 They would be on the new schedule, since they weren't a participant yet as of when the vesting formula changed. Much as coffee is for closers, vesting is for participants. CuseFan, acm_acm and Luke Bailey 3 Link to comment Share on other sites More sharing options...
CuseFan Posted May 11, 2022 Share Posted May 11, 2022 Agreed Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com Link to comment Share on other sites More sharing options...
acm_acm Posted May 12, 2022 Share Posted May 12, 2022 On 5/11/2022 at 9:08 AM, Bri said: They would be on the new schedule, since they weren't a participant yet as of when the vesting formula changed. Much as coffee is for closers, vesting is for participants. Put. The vesting. Down! Bri 1 Link to comment Share on other sites More sharing options...
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