Special participation date

[Cynchbeast]

If we have a PS plan set up 01/01/16 with a 401(k) feature effective 01/01/17, can we have a special participation date for the 401(k) for it's first year (which is actually the second year of the plan)?

[My 2 cents]

What would be the purpose of that?

[Lou S.]

What would be the purpose of that?

I image they want to give a one time immediate entry to the 401(k) feature for folks employed on 1/1/17 while keeping the year of service for the PS and having just one eligibility rule of 1 year of service for both thereafter.

[ETA Consulting LLC]

You may, but it'll take some crafty document work. If I were to do it, I'd restate the plan from a PS to a 401(k) effective January 1, 2017 (and include the eligibility provision effective then). This would prevent the open eligibility from being applied before January 1, 2017. Hence, it may take two separate adoption agreements (one initial and another a year later) to accomplish it.

Good Luck!