Service

[fiona1]

Service for an adopting employer on a multiple er plan?

[J Simmons]

If its service being counted for eligibility, then you count all service with the newly adopting employer. That doesn't depend on predecessor or prior employer service being counted.

It is the same as it would be if the employer were adopting a new, single employer plan.

If its service being counted for vesting, then whether you'd count the service for the newly adopting employer before it adopted the multiple employer plan would depend on what the multiple employer plan documents provide. If it states no 'pre-plan service' with no further specification, that's vague because it could mean no service is counted before the multiple employer plan was first set up or just no service is counted with an employer before the employer adopted the multiple employer plan. Since the plan administrator must operate the plan in the interests of the participants, I think you'd be safer going with the interpretation that such a provision disregards service before the multiple employer plan was set up.