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Per the obvious citation, when amendment of vesting schedules occurs, the emendations must allow for the apt extant participants to retain the vesting schedule as if unaffected by the amendment, at least perhaps for balances already accrued. The salient participants entail the participants who had provided suitable amounts of service, the excerpt herein lacks adjustment for subsequent amendments reducing the anticipated service favorably for the participants. URL https://www.ecfr.gov/current/title-26/part-1/section-1.411(a)-8#p-1.411(a)-8(b)(3) Citation 26 CFR 1.411(a)-8(b)(3) (b) Election of former schedule — (1) In general. Under section 411 (a)(10)(B), for plan years for which section 411 applies, if the vesting schedule of a plan is amended, the plan will not be treated as meeting the minimum vesting standards of section 411 (a)(2) unless the plan as amended, provides that each participant whose nonforfeitable percentage of his accrued benefit derived from employer contributions is determined under such schedule, and who has completed at least 5 years of service with the employer, may elect, during the election period, to have the nonforfeitable percentage of his accrued benefit derived from employer contributions determined without regard to such amendment. Notwithstanding the preceding sentence, no election need be provided for any participant whose nonforfeitable percentage under the plan, as amended, at any time cannot be less than such percentage determined without regard to such amendment. (3) Service requirement. For purposes of subparagraph (1) of this paragraph, a participant shall be considered to have completed 5 years of service if such participant has completed 5 years of service, whether or not consecutive, without regard to the exceptions of section 411(a)(4) prior to the expiration of the election period described in subparagraph (2) of this paragraph. For the meaning of the term “year of service”, see regulations prescribed by the Secretary of Labor under 29 CFR Part 2530, relating to minimum standards for employee pension benefit plans. https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XXV/subchapter-D/part-2530 Seemingly periods of service remain barred for this situation. To describe the garbled jargon, while 29 CFR Part 2530 features the term "period of service", the illocution/intent therein seems inconsistent with the use of said term to indicate the reckoning of service lacking logging of provided hours, rather as long as the employment relationship remains intact, service accrues. This situation has disadvantages to individuals who provide 1K hours to the endorsing entity during a plan year while departing prior to the conclusion of the plan year. URL https://www.ecfr.gov/current/title-26/part-1/section-1.410(a)-7#p-1.410(a)-7(a) Citation 26 CFR 1.410(a)-7(a)

The Plan provides that if a participant works past age 65, no retirement benefit will be paid until actual retirement, subject to any required minimum distributions. Once the participant retires, distributions begin and the participant receives an actuarially increased benefit. The Plan is frozen. The Plan Sponsor wants to amend the Plan to force distribution at age 65. Would such an amendment be an impermissible cutback?

I know you cannot amend the allocation methodology once someone has satisfied the accrual requirements for a particular year. In this case, there is a 1000 hour requirement for accrual of the NE. I thought there was guidance issued by the IRS about 6 - 8 year ago where they specified that if the amendment was done by May 15th (Calendar year plan), the amendment was permissible even if someone had worked more than 1000 hours. I cannot find anything to support this now. Does this sound familiar to anyone?