I am working on a Calendar Year CB plan that has an accrual requirement of either 500 hours OR Employment on the last day of the Plan Year.
The plan Froze and terminated mid-year, and only one HCE met the 500 hours requirement.
I know the Termination date creates a short Plan Year for the purposes of funding, but does it also create a short plan year for the accrual period?
Did the participants employed as of the termination/freeze date with less than 500 hours meet the requirements for accrual or do I have to amend the plan and lower the hours requirement? I don't see any guidance for this in the freeze amendment.
Thank you