Changing NRA and adding ERA

[TBob]

If a 401(k) plan that currently has the NRA set to 59 1/2 wanted to change NRA to age 65 and add an early retirement age of 59 1/2, would that constitute a cutback in benefits? There are no ISW provisions tied to NRA. The reason for the change is tied to a change from a pro-rata profit sharing allocation to a cross tested one.

[John Feldt ERPA CPC QPA]

The Normal Retirement Age is merely for 100% vesting purposes then, since you say no in-service provisions are currently tied to it. If the early retirement date also applies 100% vesting, then I see no issues.