Form 5500, item # 7h

[Guest CharlieLaur]

Looking for some feedback on how you handle this question:

Item # 7h: Number of participants that terminated employment during the plan year with accrued benefits that were less than 100% vested.

Do you include participants in this item solely on the basis of whether they are less than 100% vested or do you also take into account whether they actually have a non-zero accrued benefit (account balance)?

Example # 1: Participant in profit sharing plan is 0% vested but has a zero account balance due to the fact that he entered the plan but never received an allocation of employer contribution or forfeitures. Should he be included in item # 7h?

Example # 2: Participant in 401(k) Plan has account balance attributable to salary deferrals (100% vested) but has no account balance attributable to employer contributions/forfeitures (20% vested). Should he be included in item # 7h?

Thanks for your thoughts!

[WDIK]

http://benefitslink.com/boards/index.php?showtopic=31387