Defined Benefit Termination - $0 Accrued Benefit

[pixiebear]

We are terminating a defined benefit plan and have some participants with $0 accrued benefit. The Plan Sponsor has decided to file for approval with the IRS and we are filing with the PBGC. When do we consider the participant with no accrued benefits paid out of the plan? Would it be on the termination date or once we get approval from the IRS and pay out the participants with accrued benefits?

[CuseFan]

2 hours ago, pixiebear said:

participants with $0 accrued benefit

Active/employed participants? On what basis is their A/B zero - is this a floor/offset where their benefit is fully offset? If you have to count them (need more facts to verify) then I would say they are deemed paid when all others are paid. 

[pixiebear]

They are actively employed participants. They have no accrued benefit because participation was not frozen when the benefits were frozen so they were eligible for the plan but didn't accrue any benefit.

[david rigby]

... or an employee became a participant and then the plan was frozen before that participant reached any service accrual.