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DB plan with maybe 15 retirees receiving monthly payments was amended in 2002 to provide that all retirees who had been retired for 5+ years receive a 7% pension increase. I'll call it a COLA.

Two of the retirees did not qualify for the 5 year rule. One was the former President, the only former HCE who is retired.

Client wants to give a 7% COLA in 2004 to the two who did not qualify in 2002.

Is this discriminatory? Is there some type of coverage problem? How do the testing rules for former employees apply here?

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