Very quick question regarding vesting and terminated participants and NRA?

[Lori H]

If a participant terminates at age say 63 with 60% vested in their account, leaves their account in the plan and does not take a distribution post age 65, are they 100% vested?

Thanks

[ETA Consulting LLC]

If a participant terminates at age say 63 with 60% vested in their account, leaves their account in the plan and does not take a distribution post age 65, are they 100% vested?

Thanks

Up to the plan. Per law, 100% vesting applies to "EMPLOYEES" who reach Normal Retirement Age under the plan; not "participants". That appears to be a huge difference. The plan, however, "may" be written to say participants, but the law (as written) requires 100% vesting to "employees" at NRA.

Good Luck!