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Found 3 results

  1. A non-electing church plan wishes to increase normal retirement age for most participants, effective for already accrued benefits. I know the plan is not subject to 411(d)6, so no cutback issue. Any other issues besides potentially upsetting participants?
  2. Can an employer amend their tiered-vesting match to give immediate 100% vesting to only actively employed participants' balances? Put another way, can an employer make all match balances for only active employees 100% vested, while keeping termed participants on the existing tiered vesting schedule? Note this full vesting would be on existing balances as well as future match contributions for active employees. I'm a bit rusty on protected benefits but don't immediately see where any accrued non-forfeitable benefits are being reduced in any way. Any insights and guidance are most appreciated, as always!! Thanks!
  3. As we are now in the DC restatement cycle, I use this as an opportunity to formally review Plan provisions with my clients to see what is working for them and what might want to be changed (I discuss things with them every year but this is more formal). Taking aside the issue with changing safe-harbor plans mid-year, I know there are certain provisions that cannot be changed if it makes it worse for participants. Retirement benefits is the first that comes to mind. Typically, I could use a logical rule that says if it is going to "take away" a benefit from existing participants, then it is not allowed to be removed. Is that a rule set in stone? What if a client is sick of handling loan repayments? Could they remove a loan provision going forward? I could argue that existing participants only deferred in the past because they knew they would have access to the money. But is that stretching it? Besides the above, is there any list of specific provisions that can NOT be removed or made more strict when doing these restatements? Thanks in advance.
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