changing a vesting schedule

[Guest JBarid]

This may have been addressed before, but I can't find anything in the forum....

I have a client who has had 100% immediate vesting for their employer match. They are moving into a new doc with me and would like to change their vesting from 100% to 50%, 75%, 100% over a 3 year period.

I realize that you cannot take away benefits from a participant after it's been communicated to them, but can the employer create a new source, "new employer match" where from 1/1/07 on, the new vesting schedule will be attached?

The employees who are already employed as of the new doc would be deemed 100% vested already and any new employees that they hire in 2007 would go on the new vesting schedule.

Is this allowable? I have read sec 1.411(a)-8 and I think it is.....any other regs out there relating to this?

Thanks!