Participant count for frozen 401(k) plan?

[John A]

How is the participant count determined for a frozen 401(k) plan? Can all employees who have not met the eligibility requirements and reached an entry date as of the date of the freeze be ignored?

[Guest ersf]

Yes, employees who did not meet eligibility at the time of the freeze are not considered participants.

Participants would be:

1. active employees with an account balance

2. terminated employees with an account balance

3. active employees who were eligible to participate at the time the plan was frozen.