Proposed 415 regulations

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In the poposed 415 regulations, post severance compensation paid within 2 1/2 months after seperation from service can be counted for limitation years on or after January 1, 2005.

Am I apply the guidelines correctly?

A participant terminated December 28, 2004. On the 2005 census provided by the client, this participant has the same termination date, zero hours reported, salary of $300, deferrals of $25 and match of $5.

Do I change the termination date to 1/1/05 and include this person in my ADP/ACP test???

Your thoughts would be greatly appreciated.