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A client established a brand new 401(k) plan effective 1/1/2016. According to this new plan, plan document, · All service with the employer were counted for all purposes · Service crediting methods for all purposes was elapsed time method · Eligibility was 1 month and entry with 1st day of the month following or coinciding for all contributions · 2/20 vesting schedule Six month later, 7/1/2016, this client decided to change the TPA and add a New DB plan. To simplify the combo plan testing, the new TPA changed Service crediting method with ultimately affected the vesting. According to the restated 401(k) plan, plan document · Service from the effective date of the plan were counted for all purposes · Service crediting methods for all purposes become Hours of Methods · Eligibility stays the same for deferral but changed to 1 YOS with dual entry, 1st & 7th month, for Employer contribution · 2/20 vesting schedule The client financial advisor suggested it is ok to go with the restated vesting since this is the new plan. I have hard time to buy client’s financial advisor suggestion in light of IRC §411(d)(6) anti-cutback Regulations. The reason is that 90% of the employees had at least 1 year of service and entered to the plan on the effective date of the plan, 1/1/2016. I would think all full-time employees/plan participant will have at least 20% in their employer contribution by 12/31/2016. Is this not the case?