Forfeiture Timing

[Guest Kelly44030]

I'm pretty familiar with how and when plan level forfeiture accounts need to be used. My question is regarding participant level forfeitures. Are forfeitures after a 5 year break required to be completed within a certain amount of time? I know when they CAN be completed but is there any guidance about WHEN they MUST be completed?

Thank you.

[ETA Consulting LLC]

Some things are driven by the Code and Regulations while others are driven by the plan's written terms. I believe your issue is one that is purely driven by plan terms. The code does define a forfeiture break while allowing flexibility for when actual forfeitures are made. I believe your timing issue should be address in the document.

Good Luck!