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Geez, why make it complicated? Think of BOTH as a minimum allocation as: one-seventh, one-sixth, one-fifth, one-fourth, etc.

Here's an idea: since the "higher powers" don't know the rules and (implied above) don't believe what has been presented here, they should hire @Carol V. Calhoun to provide them some legal advice.

Exactly, so w/o interest 1/7 of $105k is $15k in year one, 1/6 of $90k is again $15k in year two, so w/o any interest all years are $15k. With gain/loss, year two is 1/6 of whatever that balance is. If 10% gain, then 1/6 of $99k is $16,500 for year two. And so on.

A document available in the website display of the Federal Register includes a table of contents, with hyperlinks. Clicking on a table-of-contents hyperlink navigates to the particular bit of text in the explanation for the proposal, or on the last bits, to the text of the proposed rule. https://www.federalregister.gov/documents/2025/01/13/2025-00350/catch-up-contributions#sectno-citation-1.414(v)-1 Also, a document is available with these formats: JSON: Normalized attributes and metadata; XML: Original full text XML; MODS: Government Publishing Office metadata. But to see an integration of what a rule would become if the proposal is adopted, one needs CCH/Wolters Kluwer or another commercial publisher.

If 1000+ hours is already accrued (assuming the plan has 1000+ hour requirement - plz check the document) and there is no last day rule within the MPP, isn't there a 2025 contribution requirement? As Bri said, if to freeze or terminate, 204(h) notice is required. As Cusefan said, best to terminate and start a 403b plan as 401a plan may not be merged/converted into 403b plan, logically speaking. Can you run MPP and 403b concurrently? If yes, must watch for 25% deduction as well as 415(c) limits. Sorry do not remember all the MPP to PSP conversion details from 23+ years ago that was allowed with EGTRRA restatement - fuzzy memory but it was done all the time but possibly before 1000+ hour requirement.

The 204(h) notice is certainly an important part of the process. Are you using a document provider? You might have access to some boilerplate language for the changeover, but specifically referencing the required grandfathering of protect benefits.

Remember that there might be two bodies of law to meet, not only tax law but also ERISA’s title I. Under tax law, there might be an I.R.C. § 72(p) failure, a § 4975 nonexempt prohibited transaction, and a § 401(a) failure to administer the plan according to the written plan. Under ERISA, there might be a § 406(a) nonexempt prohibited transaction, and a § 404(a)(1)(D) breach of not administering the plan according to the documents governing the plan. Read EBSA’s 2025 Voluntary Fiduciary Correction Program to consider whether there might be an opportunity to coordinate tax law and ERISA corrections. https://www.govinfo.gov/content/pkg/FR-2025-01-15/pdf/2025-00327.pdf Consider whether a failure was an “eligible inadvertent failure” and, if so, what opportunities SECURE 2022 § 305(b) might allow. Get the advice of a lawyer who’s independent of the recordkeeper. Although ordinarily a lawyer doesn’t accept a fee from a payer other than the lawyer’s client, one of the recognized variations is payments under an indemnity obligation. This is not advice to anyone.

Typically one would remain the sponsor of the current plan and the other would spin off into its own plan. The spin off would likely be a short plan year unless crafted carefully at 1/1. But that’s just the way I would have done it.

Yes, it can be. But the existing benefit forms must be preserved, at least with respect to the portions of people's accounts derived from contributions made prior to the change. So even though the plan is now a PSP, it will be paying life annuities/joint and survivor annuities.

Terminating the MP is probably the best option regardless, otherwise, a transfer of those accounts (versus an elected rollover) would require continued separate tracking and future annuity normal form requirement.

You can't merge a 401(a) plan such as a money purchase plan with a 403(b) plan. You could leave the money purchase plan in place for the old money and just have the new money go into the 403(b) plan, but that would involve a lot of administrative hassles. Or you could terminate the money purchase plan and allow people to take their money, potentially with an option to roll it over into the 403(b) plan.