Statutory Plan Entry

[Gilmore]

A Plan operates for the first several plan years as a calendar year plan with a 6 month wait. To make things easier administratively (enrollments, etc) they set up dual entry dates of April 1 and October 1.

Later the Plan is amended to a one year wait. If the entry dates remain April 1 and October 1 is this now a violation of the statutory entry?

As always, thanks for any insight.

[Blinky the 3-eyed Fish]

Yes, it is. My recollection is that one of entry dates must be the first day of the plan year.

Ah, I went and looked something up. See 410(a)(4).

[Gilmore]

Thanks very much for the reply.