Early Retirement Age

[baileybear]

If a plan document was restated and removed the early retirement age provisions (fully vested and entitled to a contribution if terminated and met ERA), is this a protected benefit for those plan participants prior to the restatement.

[CuseFan]

I know in the DB world that you cannot eliminate early retirement benefits with respect to benefits that already accrued.

The parallel is that you could not remove the accelerated vesting for account balances as of the effective date of the amendment (or adoption date if later). The allocation entitlement provision can be eliminated prospectively for everyone, effective 1/1/2024 assuming any 2023 amendment might result in a cutback. You could change an entire plan that had no allocation conditions in 2023 to 1000 hours and last day provisions in 2024 for everyone provided it was amended timely.