Client has a safe harbor plan that currently states that employee is eligible for safe harbor match as of the entry date following completion of first hour of service. Under Section III.D.2. of Notice 2016-16, can you amend the plan PROSPECTIVELY mid-year to require NEW employees to complete a year of service before becoming eligible for the safe harbor match? I believe that the guidance allows it, but I am curious as to whether anyone has done this.
If yes, does client need to provide a new safe notice to existing participants?
Thanks!