vesting on individual account statements

[Guest Margaret25]

What are other TPA's using for vesting on individual accounts statements as far as which year to apply on the upcoming statements (12/31)?

We are comtemplating using 12/31/2006 vesting information then updating as census information for 2007 is received but don't see any clarification as to whether or not this would be appropriate.

[J Simmons]

For the yearly individual benefit statements (individual account plans that do not allow participant direction of investment), the DoL recently issued Field Advisory Bulletin 2007-3 that such will not be due until the time the Form 5500 is timely filed. That will give TPAs seven months or more after 12/31 to determine the vesting as of that date in the plan year being reported, and put that updated vesting information in the individual account statements for that plan year.

[Guest Kevin1]

J. Simmons

Section 105 states benefit statements must include the following information:

1. based on the latest available information, the total benefits accrued and the vested percentage of such benefits (or the earliest date on which benefits will become vested), and .....

I agree that if you want to accumulate the 2008 hours you can update the 2007 statement with that data. Or if the participant is 40% vested in 2007 state that and that he will be 100% vested in 2010 if he works 1,000 hours per year in each year after 2007 (or other appropriate wording).