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For off-calendar year plans that use anniversary year for the first eligibility computation period (ECP) and plan year thereafter, when is the first date an employee could become eligible as a LTPT employee? Example: · 9/30 plan year end, ECP switches to PY after the first ECP, semi-annual entry for LTPT EEs · Participant hired 7/1/2021. · ECP 1 = 7/1/2021 – 6/30/2022 · ECP 2 = 10/1/2021 – 9/30/2022 · ECP 3 = 10/1/2022 – 9/30/2023 · Assuming Participant had at least 500 HOS in each ECP above, should this participant have entered on 10/1/2023? Do off-calendar year plans need to use anniversary year for 2021 - 2023 to avoid this result? Just thinking about SECURE 1 interim amendments, which many have already done! SECURE says: (b) EFFECTIVE DATE.—The amendments made by this section [112] shall apply to plan years beginning after December 31, 2020, except that, for purposes of section 401(k)(2)(D)(ii) of the Internal Revenue Code of 1986 (as added by such amendments), 12-month periods beginning before January 1, 2021, shall not be taken into account. Presumably, that means 12-month periods (ECPs) after 12/31/2020 DO count for LTPT purposes.
