Group classifications; timing of determination?

[AndyH]

I'd like to know how others handle changes to allocation groups.

For example, if an allocation group includes all officers, and someone becomes an officer mid-year, would the person be in the officer group for all of the year, none of the year, or would an apportionment be made?

Our (volume submitter) documents don't explicitly say. Does Corbel's specify a determination date? How do others handle mid year changes?

[actuarysmith]

I would take the view that it was their status as of the allocation date.

[AndyH]

I'm inclined to do the same, but I have a concern about 411(d)(6) and excessive employer discretion if the plan does not have a last day requirement and the groups are not specifically defined.

For example, if a group is "senior management", or "executive management" or the like (which I don't like but have inherited in many plans), I think there is excessive employer discretion if the determination date is the last day of the year.

Even if there are groups such as officers this creates employer discretion if the authority is nominal. Does this become a 411(d)(6) issue? Maybe my concerns are unwarranted?

If the plan has a last day employment condition, I wouldn't have the same concerns.