converting a DC to a DB plan

[dmb]

When amending a DC plan to a safe harbor DB plan is it possible to use service from 5 years prior to the effective date of the DC plan or is the 5 year rule only from the effective date of the DB plan?? If you can only use the 5 years prior to the DB effective date, what needs to be done to allow all prior service as far as testing and document issues??

Thanks.

[Guest Keith N]

First, as far as I know, you are not permitted to "amend a DC plan into a DB plan". They must be seperate plans. Typically the DC plan is terminated and a new DB plan is created.

Secondly, the 5-year past service rule is a safe harbor. You would be permitted to use more than 5 years, but you would be required to demonstrate that it is non-discriminatory.