Unfreezing a Frozen Plan

[smm]

Currently, DB plan is frozen. Sponsor wishes to "unfreeze" the plan for current participants only. Assuming that there are no discrimination/coverage/(a)(26) issues, is this permissible? Assuming that it is, can it be done retroactively to allow service/benefit accruals for the prior plan year? Once again, assuming no discriminatin, coverage, etc. issues. Am I missing anything?

Thanks.

[AndyH]

Yes, you can certainly unfreeze a plan, and I don't see a problem granting one year of past service credit.

You could always set up a new one and do that, so I don't see anything on the surface that creates a problem. The discriminatory timing of amendments is the only thing that comes to mind as a potential problem, but that seems possible to overcome unless you have a particularly unusual fact pattern.