Equivalent Vesting

[RRB]

Hi,

I am assuming that a (3 year cliff vesting schedule), (a 20% after 2 years and 100% after 3 years vesting schedule), a (2% after 1 year, 40% after 2 years, and 100% after 3 years vesting schedule), and a (25% after 1 year, 50% after 2 years, and 100% after 3 years vesting schedule) would be considered equivilant such that Benefits Rights and Features testing would not be required.

Any thoughts?

[Tom Poje]

I'd have my leanings against such logic.

1.401(a)(4)-11©(2) is pretty specific which schedules are equal. (Comparing the two minimum vesting schedules with no modifications)

if you are using logic that says the plan is providing better than the minimum, then would you also hold that a 3 yr cliff is equivalent to 98%/1 99%/2 100%/3yrs