EE 1: 5 years
EE 2: 3 years
EE 3: 2 years
EE 4: 2 years
At first it looks like only 2. But EE 4 turned 62 in 2013 and became 100% vested at NRA. So, now you have three.
Just my guess.
Do I follow this correctly?
HC 100% -> A
HC 60% - > I
HC 40% -> B
I 60% -> B
Wouldn't that translate to HC pass through ownership from I being 60% of 60% = 36%
So HC 40% (Direct) + 36% (Indirect) = 76% -> B < 80%, thus no CG?
Or am I off base on my analysis?
If memory serves, ... you now have 5 separate accounts in the plan, one each for the benefit of each beneficiary. That would be 5 accounts, all in the name of the deceased participant, each one FBO a different beneficiary. And what QDROphile said.