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I agree with all of the foregoing. I just wanted to add that the anti-cutback rule would apply only if a plan amendment retroactively eliminated or reduced a participant's accrued benefit or an optional form of distribution, unless, in the case of an optional form of distribution, such amendment is specifically authorized by IRS regulations located at Sections 1.411(d)-3(b) - (f) and 1.411(d)-4, Q&A-2. For purposes of determining whether a plan has been amended to reduce or eliminate an optional form of distribution, plan mergers, consolidations, spinoffs and transfers to a different plan are generally treated as amendments. Prospective freezing, reduction or elimination of accruals and optional forms of distribution are generally permitted, subject to the risk that the affected participants may be deemed to have been impacted by a partial plan termination and propecitvely reducing or eliminating accruals may require a 204(h) notice to be furnished to impacted participants.

For a short plan year the 401(a)(17) compensation limit and 415 limit are prorated 10/12. I'm not sure, but I thought a partner's earned income is deemed to all be earned on 12/31, so you don't prorate income for a short year but you limit the income according to prorated limit.

Keep in mind the long-term part time employee rules that will take effect next year.

VCP

One-PERSON option. Just sayin'