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Posted

Plan allows for in-plan Roth rollovers at any time as long as the funds are 100% vested. 

Is this a protected benefit?

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

Posted

But if you had in the plan, allowed an owner or HCE to take advantage of, and then amended out - you might have a discrimination issue, especially if the provision was not in the plan for a while, or was amended out before NHCEs became fully vested and were able to utilize.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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