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Change of Vesting Schedule with EGTRRA


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Guest ERISA Geek
Posted

We have a client that currently vests on a 5-year cliff schedule. With the EGTRRA amendment they want to change to a 6-year graded schedule.

Does this change consititute an IRC Section 411(d)(6) cutback?

If it does, is an ERISA Section 204(h) notice required?

Posted

411(d)(6) is concerned with the benefit. I suggest your question should focus instead on 411(a)(10). http://www.fourmilab.ch/ustax/www/t26-A-1-...-D-I-B-411.html

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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