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Jimmy Slones

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  1. 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
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