In-service and 5 years participation

[Ajillity]

How is 5 years of participation figured if a plan restricts in-service distribution to age 59 1/2 and 5 years of participation?

What little information I could find seems to indicate using elapsed time, 60 months.  Is it permissible to count 5 years for someone with a 7-1-15 entry date as 2015, 2016, 2017, 2018 and 2019 to consider this 5 years of participation?  The plan document says 5 years, not 60 months participation.

[mming]

Unless the plan document specifically defines 'Year of Participation' or contains anything to the contrary, I think it would be acceptable to use either method as long it's done consistently.  If  the elapsed time info you have found is in the doc, however, then the requirement wouldn't be satisfied until 7/1/20.    

[Bri]

I'd also be on the lookout for any language that defines the NRA using years of participation, since that actually would mean the 5th anniversary of the first day of the plan year in which participation commenced.  (In which case you might be looking at 1-1-20, presuming the Plan Administrator wishes to interpret the plan document in a similar manner.)

[Ajillity]

I actually ran this by a document vendor who did not prepare the document in question.  NRA totally different situation because of the anniversary language.  Plan in question does not have 5th anniversary for NRA.  Regarding the 5 years of participation, they were only speaking for their documents, which are much clearer in the BPD regarding the definition of participation.

The plan in question is not elapsed time so I'm going with mming's answer.