NRA at age 65 and 5th anniv short plan year

[ESOP Guy]

I have an ESOP that defines Normal Retirement Age (NRA) as age 65 and 5th Anniversary of Participation.   When the plan started it was a 9/30 PYE.  The first PYE was 9/30/2015.  In 2016 they switched to a 12/31 PYE.  So they have a short plan year of 10/1/2016 to 12/31/2016.  

I have a person who entered on 10/1/2014 the Effective Date of the Plan.   As of 12/31/2018 he is over age 65.  

Does he have his 5th Anniversary year? 

Do you count it as PYE 9/30/2015, 9/30/2016, 12/31/2016, 12/31/2017 and 12/31/2018  which comes to 5.

Or

Do you count actual anniversaries 9/30/2015, 9/30/2016, 9/30/2017 and 9/30/2018 which comes to a count of 4 by the time the person terminates. 

It makes a difference as his YOS for vesting are at 5 as he got a YOS in the short plan year.  However, this is a 2/20 vesting scheduled so by YOS he is 80% vested.  If he has hit his NRA he is 100% vested.  

[david rigby]

The precise definition prob includes something like "...first day of the plan year that includes the fifth anniversary of plan participation".  Thus, the NRD is fixed when he/she becomes a participant, and subsequent changes in the PY have no effect.  IMHO.

[ESOP Guy]

Any other thoughts?  

I was heading towards where David went in terms of thought process.  

[NJ Mike]

Our plans, for example,  would define it as the fifth anniversary of participation.  So like David said, the change in the plan year has no effect.

Mike