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FWIW...someone had recently published n a non-Benefitslink site a different opinion. Regarding the question on terminated employees who are later rehired, any new employer contributions to the plan after rehire would be subject to the plan’s vesting schedule. The IRC and regulations merely require full vesting for the amount in the plan as of the date of the partial plan termination. Consequently, if a terminated employee leaves behind his or her plan balance and is later rehired, the plan would have to apply two vesting schedules.

Adopt an -11(g) amendment waiving the last day requirement for the 2019 employee, and a mid-year amendment waiving the last day requirement and granting additional vesting for the 2020 employee.

yes

We also have a few (very few) holdouts on this. Typically it is bad memories of an incompetent payroll service (or in-house payroll administrator) who constantly screwed up deferral changes and caused a lot of work/expense to fix.

Having both an undergraduate and masters in economics, I remember being amazed in my first Money and Banking course to find out how banks really work. They really do CREATE money utilizing what is known as the fractional reserve system. Economics is called the dismal science, and most people's eyes glazed over when us eco majors started talking to non majors in school about the things we now knew, but I still find it fascinating and often think I would have gone on for my doctorate IF the field of Behavioral Economics existed as such when I graduated my MBA in the late '70s; it didn't, and thus the career I did have.....

Bill, I don't know WHY they always go along, but I don't really offer it as an option. I tell them that is what we are doing and that's it. I also have a problem with a client who has no good reason for NOT following my advice; that may be a client that I will dump because I am their consultant and if they don't take my advice here, they may not be a good client in the long run. The problem is they think they know better than me, and that's a real problem if I can't get them over that hump. I don't have any desire to be arguing with them in the future. Now, there are lots of things that I would PREFER, but sometimes the clients actually do have a reasonable reason for what they want (for example, we have few plans that have loans, but the ones that do had "acceptable" - to me - reasons for why we needed to add that provision and do loan documentation, so not the same problem as in this example). FWIW.

I wish I could "like" this twice. I refuse to make the client's problem my problem just because their team of attorneys didn't do their due diligence.