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Maybe I'll get a new card when I renew in 2015. I'm not sure it matters because I've never had an opportunity to flash my ERPA card.

I just got my renewal card a few days ago.

Thanks. Maybe this only happens to me, but sometimes when I'm in the middle of 16 things, I get a question to which I really know the answer if I'd just take a deep breath and clear my head, but instead I give it a quick thought with a small part of my so-called brain, and suddenly find myself confused. Very annoying...

FWIW, I asked a couple of our auditors (We're a CPA firm that audits close to 200 plans) and they said there isn't any GAAP or specific information on this. The only thing they found was in the Checkpoint Tools for the audit program that said to be included as a receivable, the amount had to "be withheld from compensation during the plan year, but not remitted to the trust until after the end of the plan year." Not sure they will accept that, but that's all we could come up with.

I'm sorry, but this line made me chuckle. I don't think you had said that previously.

You can't exclude their prior service. For example a participant with 3 YOS at the time of the amendment would be 100% vested in the old money and 40% vested in the new money. Thanks I knew I wasn't thinking through it right. Too close to 10/15 for the mind to work 100%