Spencer Posted May 27, 2010 Posted May 27, 2010 Client closed a location in 2009. Their attorney advised it was not a partial plan term. I don't know the numbers yet, but for purposes of this question, let's assume that is correct. Atty prepared amendment to accelerate vesting to 100% for all participants at location that closed. Does this need to be BRF tested?
david rigby Posted May 27, 2010 Posted May 27, 2010 Probably, but you may wish to do additional research on partial terminations. For example, see http://benefitslink.com/boards/index.php?showtopic=44590, especially post #5. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
Spencer Posted May 28, 2010 Author Posted May 28, 2010 Probably, but you may wish to do additional research on partial terminations. For example, see http://benefitslink.com/boards/index.php?showtopic=44590, especially post #5. That is helpful, thank you. I have more info now. Only non-HCEs had vesting accelerated; HCEs were already 100% vested. Client thought having a partial plan term sounded bad. Anyway, they have guidance from an ERISA attorney (I wasn't aware it was an ERISA atty yesterday). Thanks again!
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