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Church Org A has a DB plan, and Church Org B has a DC plan. Church Orgs are related but not in the same controlled group. Both plans are nonelecting church plans. Assume Church Org A's DB plan allows for maximum service credit of 30 years for purposes of benefit accruals. Can Church Org A's DB plan be amended to count service credited under Church Org B's DC plan against the maximum. For example, an individual who has 25 years of service under Church Org B's DC plan leaves the employment of Church Org B and is hired by Church Org A. Under Church Org A's DB plan, the maximum service credit the individual can receive under the DB plan is 5 years (30 years- 25 years). Any issues with this arrangement?

Posted

Why not? You don't have to worry about non-discrimination rules, so that only leaves the potential for state labor issues and civil right issues.

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