Short Plan Year and prorated limits

[perplexedbypensions]

Hi all, happy New Year.

I am working on a PSK plan with a short PY 7/1/19 - 12/31/19.

I am prorating the 415 limit and 401(a)(17) comp limit to 50% of the annual limit.

I did not prorate the 1000 hours for plan eligibility or the 402(g) limit.

I am questioning the other provisions with hours requirements:

Does the 1000 hours for vesting need to be prorated to 500 hours?

The plan requires 1000 hours to receive an allocation of the PSC.  Does this need to be prorated to 500 hours for allocation?

Thank you for the help.  My brain does not seem to be working.  I truly think that I did know this once... long ago....

[justanotheradmin]

I usually start by reading the plan document ( including the basic plan document). Ours specifies which limits are pro-rated and which are not for short plan years. It also differs if the short plan year is the initial year of the plan's existence or not. 

Maybe your document also includes those details. 

[Larry Starr]

2 hours ago, justanotheradmin said:

I usually start by reading the plan document ( including the basic plan document). Ours specifies which limits are pro-rated and which are not for short plan years. It also differs if the short plan year is the initial year of the plan's existence or not. 

Maybe your document also includes those details. 

Gee, what a unique idea! Let's see if the plan document deals with it.

Lo and behold, I bet it does.

The following is found in our Year of Service definition - FIS volume submitter doc (the first sentence is applicable to vesting; the second to accrual, which may or may not be in your document depending on what options you elect):

Notwithstanding the foregoing, for any short Plan Year, the determination of whether an Employee has completed a Year of Service shall be made in accordance with Department of Labor regulation §2530.203-2(c). However, in determining whether an Employee has completed a Year of Service for benefit accrual purposes in the short Plan Year, the number of the Hours of Service required shall be proportionately reduced based on the number of full months in the short Plan Year. 
 

[perplexedbypensions]

I had looked in the doc, but quite obviously, in the incorrect places, as I did not see it.  Thank you for the advice.