Vesting on new DB Plan

[Craig Garner]

Plan sponsor has an existing age-weighted Profit Sharing plan, which has been around for a number of years. The time has come to adopt a DB plan, in addition to the PS plan. All the same folks in the PS plan will also be in the DB plan. The PS plan is, of course, Top Heavy. When the DB plan is adopted, must all prior service be counted for vesting or can the plan exclude service prior to adoption for vesting purposes?

Thank you to all who take the time to help out on this website!!

Craig

[Andy the Actuary]

Plan sponsor has an existing age-weighted Profit Sharing plan, which has been around for a number of years. The time has come to adopt a DB plan, in addition to the PS plan. All the same folks in the PS plan will also be in the DB plan. The PS plan is, of course, Top Heavy. When the DB plan is adopted, must all prior service be counted for vesting or can the plan exclude service prior to adoption for vesting purposes?

Thank you to all who take the time to help out on this website!!

Craig

see 411(a)(4)©

[John Feldt ERPA CPC QPA]

See also §1.411(a)-5(b)(v)