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Termed/Retired prior to Normal Retirement Age


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We have a question into Relius asking why the system is making an employee 100% vested when said employee terminated prior to Normal Retirement age.  Employee does not have the required 6 years vesting service to be 100%.  It appears that Relius is only looking at age of the employee and not taking into consideration term date......

However, he is the response we get.

"The participant still has a balance and a forfeiture event has not occurred. So, if they reach retirement age with their balance still in place, they DO become 100% vested as they have satisfied the plan's requirements. That is what the regs say. Unless their document has a provision that excludes terminees who reach retirement age from becoming fully vested, but they should check their document and check with their own experts--then Relius is doing things correctly."

What does a forfeiture even have to do with this?

What regs?

It's a Relius Document that says the employee would need to be employed on or after your Normal Retirement Age.  The employee did not meet employed at Normal Retirement Age.

Am I missing something about a forfeiture event and not being employed at Normal Retirement Age?  This would be new to me if I am.....

Thanks

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And you've got the "service for vesting" filled with that smaller number of years, rather than the plain "service" number of years?  And it didn't already have the 100% vesting error in the prior plan year's file, so that it would have just rolled that forward?

I don't recall if I've seen that kind of thing screwed up before, so I'm at least pondering a "verify absolutely everything in the employee record" approach and hope Relius would do it right if it is just a case of missing a datum spot in the software.  Heck, I've messed up stuff myself by entering 2003 for termination dates instead of 2023 already this year.

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