In-plan Roth: protected benefit and recordkeeping

[Flyboyjohn]

Any guidance or opinions on whether offering an in-plan Roth rollover/conversion/transfer becomes a protected benefit that will be difficult to remove once added?

Anybody keeping a list of which recordkeeping platforms are now capable of doing the recordkeeping? We're concerned about adding the feature in the document without confirming the recordkeeping capabilities.

[Belgarath]

From IRS Notice 2013-74:

Q–7. Would a plan with an ongoing qualified Roth contribution program violate § 411(d)(6) if it discontinued in-plan Roth rollovers?

A–7. No. An employee’s ability to make an in-plan Roth rollover is not a section 411(d)(6) protected benefit. However, an amendment to eliminate in-plan Roth rollovers is subject to the rules in § 1.401(a)(4)–5, relating to whether the timing of a plan amendment or a series of plan amendments has the effect of discriminating significantly in favor of highly compensated employees or former highly compensated employees.