204(h)

[Guest TuckerB]

Is a 204(h) notice required to a group of employees who are going to be transferred from the parent company to one of its subsidiaries and will no longer be participants in the Company's DB plan. The subsidiary has its own benefit plans and a DB plan is not one of the plans. Thanks.

[J Simmons]

204h notice is only needed if the reduction in benefit accruals is due to a plan amendment, not changes of independent significance in other aspects of employment that render the individual to accrue less or none in the future.