Special Deferral effective and plan entry

[BG5150]

I am writing a plan with effective date 1/1/2017, but a deferral effective date of 4/1/17 so I can implement an EACA.  Eligibility is currently 21/1 with plan entry dates of 1/1 and 7/1.  Do I have to do anything to make those who would have entered on 1/1 actually active on 4/1?  (Because 1/1/17 there were no deferrals allowed.  Absent any specific language, would those eligible on 1/1 be able to make deferrals on 4/1, or would they have to wait until 7/1?)

[K2]

I would just make the effective date for deferrals 4/1, and then any eligible participant at that date could start deferring.  I assume your document will allow deferral changes at least quarterly, so that people can "enter" on 4/1 by changing/implementing their deferral election.

[duckthing]

Offhand I'd say that if they met the entry requirements before (or on, if the entry date language is written that way) 1/1 then they entered the plan on 1/1. The plan that they entered just doesn't happen to permit deferrals prior to 4/1.

[Kevin C]

Since you are not sure, the best way would be to include language that is specific enough to make it clear what the initial entry dates are supposed to be. Our PPA VS documents have places for "other" provisions and special effective date sections that allow additional language for unusual situations.  I would expect other documents to have the same types of options.