Crediting Service in Plans with Service-Based Exclusions

[401 Chaos]

I've not yet found guidance that says this expressly but am assuming if you have a plan with a service-based exclusion for seasonal employees (including the 1 year of service fail safe provisions) but let regular employees in after 6 months of service, a seasonal employee who has been working there for 6 or 7 months and is "hired on" or continues as a regular employee rather than leaving at the end of the season would be eligible to come into the plan right away--i.e., that you count all service with the employer even if it is during a period when they are not generally in an eligible class.

[CuseFan]

That is the case. The document should say what happens when someone goes from an eligible class to ineligible class of employee and vice versa.

Think about the union exclusion. A long time union employee moves into a nonunion position, do they have to work a YOS nonunion before entering the plan? Absolutely not.

I wouldn't look for "guidance", it's just application of the rules. You are required to count all service with the employer (or control group) for eligibility and vesting.