eligibility question

[thepensionmaven]

Having a senior moment.  Participant hired 1/20/20, EC Period 1/20/20-1/19/21 - 1,000 hours credit.

Overlap is 1/1/21-12/31/21, worked 870 hours.

Plan defines eligibility for contribution as 1,000 hours OR last day.

I think she is eligible 1/1/21, and since employed on ast day of the year, must receive a contribution?

[Lou S.]

She has a year of service on 1/20/2021 and enters the Plan on the Plan's next entry date (or 1/1/2021 if the Plan has retroactive entry).

Since she has not terminated as of 12/31/2021 she would receive an allocation for the 2021 as she meets the "OR employed on the last day of the year" condition.

[Mike Preston]

I think you'll find that the latest entry date possible is 7/1/2021.  Therefore, Lou is correct.

[BG5150]

4 minutes ago, Mike Preston said:

I think you'll find that the latest entry date possible is 7/1/2021.

Could it be 7/19/21, 18 months after hire, or more specifically, 6 months after satisfying the eligibility requirements?

[Mike Preston]

Could be.  Certainly before 12/31/21.

[ESOP Guy]

1 hour ago, thepensionmaven said:

Plan defines eligibility for contribution as 1,000 hours OR last day.

I think she is eligible 1/1/21, and since employed on ast day of the year, must receive a contribution?

I agree with the above but find the "OR" the most interesting part of this whole thing.  

[Bri]

Nah, that's not *too* different from a standardized prototype's "500 hours OR last day" provision.  But sure, why "almost" guarantee 410(b) will pass, but require the 1000 instead?

[ESOP Guy]

1 hour ago, Bri said:

Nah, that's not *too* different from a standardized prototype's "500 hours OR last day" provision.  But sure, why "almost" guarantee 410(b) will pass, but require the 1000 instead?

Yeah I forgot about standardized prototypes.   I haven't worked on that kind of a plan document for over 15-20 years.