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Posted

A 401(k) Plan currently has a 6 year graded vesting schedule for the Profit Sharing Contribution.

The Plan Sponsor wants to amend the Plan to read "Employees hired prior to and including 12/31/06 are 100% vested in the Profit Sharing Plan".

Is this allowed?

Posted
A 401(k) Plan currently has a 6 year graded vesting schedule for the Profit Sharing Contribution.

The Plan Sponsor wants to amend the Plan to read "Employees hired prior to and including 12/31/06 are 100% vested in the Profit Sharing Plan".

Is this allowed?

It's not a cutback, so no 411d6 problem.

Will this amendment, given its timing, disproportionately favor HCEs? If so, then it could be discriminatory. 1.401a4-5.

John Simmons

johnsimmonslaw@gmail.com

Note to Readers: For you, I'm a stranger posting on a bulletin board. Posts here should not be given the same weight as personalized advice from a professional who knows or can learn all the facts of your situation.

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