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A plan has 100% vesting right now, all HCEs are under this schedule and all NHCEs. To change vesting to a 3 year cliff, you could do this for new hires as of July 1. There is no cut back in vesting. However I believe you to test the plan under BRF testing. As long as the prior better schedule covers at least 70% of the NHCEs then you are ok correct? IF not then you can run the nondiscrim class. test and use the safe harbor %.

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