EGTRRA and minimum match vesting

[Guest GS1100]

Can someone confirm that minimum vesting under EGTRRA will apply to match contributions from previous years and not only contributions form 2002 on?

Thanks

[MWeddell]

It depends what's in your document (or more precisely what will be in your document when your good faith EGTRRA amendment is adopted by the end of the 2002 plan year). EGTRRA only required that the matching contribution vesting schedule apply to contributions made in the 2002 plan year or later, but many plans voluntarily will extend the more rapid vesting schedule to older match as well.

[Archimage]

Another thing that you might consider is that keeping track of match vesting pre-2002 and post-2001 is a significant administrative burden. We advise all our clients to to make all match go to the minimum 2/20.

[MWeddell]

Having two different vesting schedules, one for match pre-2002 and another for match post-2001, doesn't strike me as a significant administrative burden. One must supply the recordkeeper with the data needed to compute vesting service. All recordkeepers have software that allow them to credit post-2001 match to a different contribution source with a different vesting schedule, so this complication doesn't impose greater administration on the employer assuming that an external recordkeeper is retained.

It certainly does make the vesting more complicated to communicate to participants. Also, this decision would presumably have been made before the 2002 plan year begins.