Multiple 403(b) plans

[Guest mbw]

An employer sponsors two different 403(b) plans. Based on how I read the regulations, the employer could not terminate one of these plans but continue to allow elective deferrals to the other one for at least 12 months. Would you agree? Can you merger the two plans, and is this essentially a plan to plan transfer?

[Guest Mr. Kite]

Section 1.403(b)-3(a) indicates that elective deferrals are treated as employer contributions, and therefore the 12-month ban on employer contributions following a terminatin in 1.403(b)-10(a) would apply to elective deferrals.

[Guest mbw]

That's what I thought.

What about the plan to plan transfer rules? Is this essentially a plan merger? Assuming we could transfer every last dollar would this effectively eliminate the first plan?

[Guest Louise76]

That's what I thought.

What about the plan to plan transfer rules? Is this essentially a plan merger? Assuming we could transfer every last dollar would this effectively eliminate the first plan?

Agreed. Your best option is to merger the 403(b) plans which I read to be a plan-to-plan transfer under the regulations.