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  1. Is there any regulation for determining who is an active participant under a professional service DB plan? It appears regulations under §4006.2 may be obsolete. I don't see any regulations under 29 USC §1321 (ERISA §4021), which sets up the exemption. I'm looking at a CB plan with 22 definitely actives, two eligibles but with a $0 HAC, and two terminated participants with accrued benefits. There are different definitions for different purposes, but the definition of "active participant" for this purpose is elusive. By some definitions there are 26 actives, 24 actives, and 22 actives. Any direction is appreciated.
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