vesting schedule change is more strict

[WCC]

I have read all the threads on this board that I can find regarding change in vesting as well as the EOB, 411(a)(10). My confusion is regarding comments that state future accurals are subject to the prior vesting schedule.

Plan sponsor decides to be generous and make everyone 100% immediately vested in a discretionary match. This has been the case for a few years. New CEO questions why this was done and wants to change vesting to a 4 year graded schedule.

Can the plan sponsor amend the vesting schedule to keep all current match 100% vested and have future discretionary match accruals subject to a 4 year graded schedule? (regardless of the record keeping struggles).

Thank you

[Lou S.]

You can change it so that future participants are subject to the 4 year schedule but folks that are already 100% vested can't be switched at this point as you'd have a 411(d) cutback.

I mean I guess you could technically move folks with less than 3 years of service to the new schedule as long as you preserve the vesting they attained under the old schedule which is ...100%.